IPA/AAPS/FIP Workshop on Quality - Indian … Saleh - WHO - Pre...IPA/AAPS/FIP Workshop on Quality...
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IPA/AAPS/FIP Workshop on Quality
Wednesday 20 and Thursday 21 February 2008The Hyatt Regency Hotel,
Mumbai, India
“Good manufacturing Practices for 21st Century ”
WHO-GMP Perspectives
By Dr Abdel Aziz SalehSpecial Adviser to the Regional Director
WHO/EMRO
WHO Constitution
International health standards
WHO Constitution Article 2:“to act as the directing and coordinating authority on international health work.”
FUNCTIONS OF WHOTo act as the directing and coordinating authority on international health workTo develop, establish and promote international standards with respect to food, biological, pharmaceutical and similar products.
Standards with respect to the safety, purity and potency of biological, pharmaceutical and similar products moving in international commerce;Advertising and labeling of biological, pharmaceutical and similar products moving in international commerce;
The Health Assembly shall have the authority to adopt concerning:
STANDARD SETTING FUNCTION
Strategy Components
Medicines policyAccessQuality and safetyRational use
ChallengesThree types of common imbalance have been identified in regulatory practice
Much more time is assigned to pre-marketing assessment than to post marketing surveillanceWhile product registration is considered a major responsibility by all the drug regulatory authorities, the regulation of drug distribution channels and information does not enjoy the same level of attentionIn many countries, GMP inspection receives more attention and resources than inspection of distribution channels
With the technical support of WHO, a postgraduate university degree course on pharmaceutical good manufacturing practices (GMP) was developed in the Islamic Republic of Iran which can be used for capacity-building for countries of the Region. Technical support was provided for training workshops on good manufacturing practices in several countries.
Some examples of WHO Technical Support
Technical support was provided for fellowships for different issues related to quality assurance and safety of medicines and vaccines, a in addition to Who publications on quality and safety of medicines.
The quality of pharmaceuticals has been a concern of the World Health Organization (WHO) since its inception. The setting of global standards is requested in Article 2 of the WHO Constitution, which cites as one of the Organization’s functions that it should “develop, establish and promote international standards with respect to food, biological, pharmaceutical and similarproducts.”
Quality of Pharmaceuticals
World Health Assembly continues to express great concern about the quality, safety and efficacy of medicines, particularly those products or active pharmaceutical substances imported into, or produced in, developing countries. In recent years counterfeit products have infiltrated certain markets in disquieting proportions. Since the founding of WHO, the World Health Assembly has adopted many resolutions requesting the Organization to develop international standards, recommendations and instruments to assure the quality of medicines,whether produced and traded nationally or internationally.
In response to these resolutions, the WHO Expert Committee on Specifications for Pharmaceutical Preparations, which was originally created to prepare The International Pharmacopoeia, has made numerous recommendations relevant to quality assurance and control.
The recommendations are essential to all concerned with the quality assurance of medicines, but separate publications over a period of years has made it difficult to recognize them as complementary parts of a comprehensive system of quality assurance.
Volume 1 of Quality assurance of pharmaceuticals: a compendium of guidelines and related materialswas published by WHO in 1997. Material relating to national drug regulations, product assessment and registration
Volume 2, first published by WHO in 1999, reproduces guidelines related to good manufacturing practices (GMP) and to theinspection of pharmaceutical manufacturers and drug distribution channels. This volume was updated in 2004, and the current version constitutes the second updated edition of Volume 2 including new texts and revisions adopted to date as WHO guidelines.
GMP are an important part of a comprehensive system of quality assurance. They also represent the technical standard upon which is based the WHO Certification Scheme on theQuality of Pharmaceutical Products Moving in International Commerce.
GMP WHO Perspectives
The first GMP text published by WHO was developed during 1967–69 upon request by WHO’s Member States and was revised in 1975. In the 1980s and early 1990s, several national and regional drug regulatory authorities issued or revised guidelines reflecting the ongoing elaboration of the concept of GMP.
WHO GMP Guidelines
Revised and expanded GMP guidelines were prepared during 1989–90, approved by the WHO Expert Committee on Specifications for PharmaceuticalPreparations in late 1990 and subsequently published by WHO.
WHO GMP Guidelines
GMP guidelines published by WHO areto be regarded as advisory in nature and may need to be adapted to addressspecific conditions in individual countries. However, if any departures fromrecommended practices are introduced, the equivalence of such alternativeapproaches should be validated.
WHO GMP Guidelines
The GMP guidelines for biological productsThe GMP guidelines for the manufacture of investigational pharmaceutical productsThe specialized GMP guidelines for the manufacture of herbal medicinal productsRadiopharmaceuticals close collaboration with the International Atomic Energy Agency (IAEA).“Guidelines for inspection of drug distribution channels”
Specialized GMP Guidelines
WHO Basic Training Modules on
GMPA resource and study pack
for trainers
GMP VIDEO.Video Supplementary Document
The video shows GMP “compliant” and “non-compliant” practices. The “compliant” part contains “non-compliant” aspects that should be identified by participants during training.
Lack of reference or identification of responsibility of key personnel
final product release for distributionvalidation not referred to and others
Inspection is closely related to other elements of the overall medicines quality assurance system: GMP, licensing of manufacturing facilities, product registration.
WHO Guidelines on Inspection
“Provisional guidelines on the inspection of pharmaceutical manufacturers” was published by WHO in 1992 along with the core GMP guidelines.
Additional guidelines dealing with the quality system requirements for national good manufacturing practice inspectorates were adopted by the Expert Committee.
WHO good manufacturing practices: main principles for
pharmaceutical products
General considerationsLicensed pharmaceutical products (marketing authorization) should be manufactured only by licensed manufacturers (holders of a manufacturing authorization) whose activities are regularly inspected by competent nationalauthorities.
Glossary
The definitions given below apply to the terms used in this guide. They may have different meanings in other contexts.
Quality management in the drug industry
The basic elements of quality management are:
— an appropriate infrastructure or “quality system”, encompassing the organizational structure, procedures, processes and resources;
— systematic actions necessary to ensure adequate confidence that a product (or service) will satisfy given requirements for quality. The totality of these actions is termed “quality assurance”.
Quality assurance“Quality assurance” is a wide-ranging concept covering all matters that individually or collectively influence the quality of a product. It is the totality of the arrangements made with the object of ensuring that pharmaceuticalproducts are of the quality required for their intended use. Quality assurance therefore incorporates GMP and other factors, including those outside the scope of this guide such as product design and development.
Good manufacturing practices for pharmaceuticalproducts (GMP)
Good manufacturing practice is 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 authorization. GMP are aimed primarily at diminishing the risks inherent in any pharmaceutical production. Such risks are essentially of two types: cross-contamination (in particular of unexpected contaminants) and mix-ups (confusion) caused by, for example, false labels being put on containers.
Main Challenges
Legal framework Qualified national expertise in GMP inspectionTeaching GMP and Quality Assurance at universitiesContinued education and on job trainingQuality system
Legal Framework
Many developing countries do not have the national expertise to develop national legal framework for GMP standard and GMP national inspection system
Developing countries usually adopt one of the recognized national, regional, or global GMP rules. WHO/GMP are generally accepted.
The development of the National Inspection Manual and the Legal Framework of the GMP Inspection system needs additional technical support.
Qualified national expertise in GMP Inspection
Most of the national regulatory Authorities in developing countries lack the necessary personnel with the appropriate qualification and expertise in developing and running an efficient national system in GMP Inspection
The available facilities and working conditions do not attract competent personnel to work in the governmental sector
Teaching GMP and Quality Assurance System at
universitiesOnly recently schools of pharmacy in developing countries started teaching basic principles of medicines Quality Assurance System and GMP inspection to the pharmacy under-graduate students
Continued Education and on Job Training
Very few countries regularly organize continued education programmeand on job training courses to GMP inspectors and other quality assurance system staff
These activities are mainly dependent on external sources from donors and UN agencies
Recommendations and Conclusions:
Establishment of national quality systemPharmacy educationProfessional development Partnership and collaboration
Quality systems Requirements for National
Good Manufacturing Practice Inspectorates
Administrative StructureThe administrative structure, membership, operation and legal status of the GMP inspectorate should be described in the quality manual. The quality manual should show how all personnel working for the GMP inspectorate, including subcontracted staff or advisers, and persons serving on committees providing advice, can maintain their impartiality
Organizational structure
The GMP inspectorate should have an organization that enables it
to maintain the capability to perform its technical functions satisfactory
The GMP inspectorate should have:Documentation clearly identifying its legal statusAn organizational chart showing clearly the responsibility and reporting structure of the inspectorate and, in particular, the relationship between its inspection and authorization (licensing) functionsA description of the means by which the inspectorate obtains financial supportA description of the relationship between the GMP inspectorate and other departments within the drug regulatory authority and other government agencies, where they operate as separate bodies.
Inspection personnelThe credibility of the GMP inspection process will depend to a large degree on the technical competence and integrity of the inspectors. The quality manual should provide up-to-date details of the names, qualifications, experience and terms of reference (job description and duties to be performed) of each member of staff engaged in the GMP inspection process
Pharmacy Education
GMP and quality system courses should be part of the core
curriculum of undergraduate pharmacy education
Partnership and Collaboration
More technical support to developing countries is needed from UN agencies and other partnersBilateral, subregional and regional collaboration has proven to be very successful in improving the national quality assurance system
Thank You
Quality SystemMost developing countries lack the comprehensive set-up of a national quality system as defined by WHO “An appropriate infrastructure, encompassing the organizational structure, procedures, processes and resources necessary to ensure adequate confidence that a product (or service) will satisfy given requirements for quality”
Quality and Safety
The quality, safety and efficacy of all medicines assured by strengthening and putting into practice regulatory and quality assurance standards
Medicines regulation and quality assurance systems
WHO ObjectiveInstruments for effective drug regulation and quality assurance systems promoted in order to strengthen national drug regulatory authorities.
The quality of medicine Varies greatly-especially in low-and middle-income countries. While most countries have a medicines regulatory authority and formal requirements for registering medicines, one-third of WHO Member Sates have either no regulatory authority or only limited capacity to regulate the medicines market.
National Drug Quality Assurance System
IPA/AAPS/FIP Workshop on Quality
Wednesday 20 and Thursday 21 February 2008
The Hyatt Regency Hotel, Mumbai, India
“Good manufacturing Practices for 21st
Century ”WHO prequalification Scheme
By Dr Abdel Aziz SalehSpecial Adviser to the Regional Director
WHO/EMRO
Outline of the presentations
WHO Medicine strategyWHO Medicine Quality Assurance
ProgrammeWHO Prequalification Project
WHO Prequalification Scheme and Local Medicine Production
Recommendations
GOAL
WHO’s goal in medicines is to help save lives and improve
health by ensuring the quality efficacy, safety and rational use
of medicines, including traditional medicines, and by promoting
equitable and sustainable access to essential medicines,
particularly for the poor and disadvantaged
Strategy Components
Medicines policyAccess
Quality and safetyRational use
WHO Medicine Quality Assurance ProgrammeQuality and Safety
The quality, safety and efficacy of all medicines
assured by strengthening and putting into practice
regulatory and quality assurance standards
Medicines regulation and quality assurance systems
WHO Objective
Instruments for effective drug regulation and quality
assurance systems promoted in order to strengthen national drug regulatory authorities.
National Drug Quality Assurance System
The quality of medicine Varies greatly-especially in low-and middle-income
countries. While most countries have a medicines regulatory authority and formal requirements for registering
medicines, one-third of WHO Member Sates have either no regulatory
authority or only limited capacity to regulate the medicines market.
Quality System
Most developing countries lack the comprehensive set-up of a national quality
system as defined by WHO “An appropriate infrastructure, encompassing the
organizational structure, procedures, processes and resources necessary to
ensure adequate confidence that a product (or service) will satisfy given
requirements for quality”
Quality systems requirements
Administrative structure
The administrative structure, membership, operation and legal status
of the Quality system should be described in the quality manual. The quality manual should show how all
personnel working for the Quality system, including subcontracted staff or advisers,
and persons serving on committees providing advice, can maintain their
impartiality
Organizational structure
The Quality system should have an organization that enables it to maintain the capability to perform
its technical functions satisfactory
ChallengesThree types of common imbalance have
been identified in regulatory practice
Much more time is assigned to pre-marketing assessment than to post marketing
surveillanceWhile product registration is considered a
major responsibility by all the drug regulatory authorities, the regulation of drug distribution channels and information does not enjoy the
same level of attentionIn many countries, GMP inspection receives
more attention and resources than inspection of distribution channels
Fact sheet N°278May 2004
The WHO prequalification project
The Prequalification project, set up in 2001, is a service provided by the World Health Organization (WHO) to facilitate access to medicines that meet
unified standards of quality, safety and efficacy for HIV/AIDS, malaria and tuberculosis.
The availability of quality, safety and efficacy of medicines is a major concern of WHO. To ensure that quality pharmaceuticals are available, WHO sets norms and standards, develops guidelines
and advises Member States on issues related to quality assurance of medicines in national and
international markets. WHO assists countries in building national regulatory capacity through
networking, training and information sharing.
These activities have been endorsed and supported by Member States through
numerous World Health Assembly resolutions
The Prequalification project is part of these activities and mandate. It does not intend
to replace national regulatory authorities or national authorization systems for
importation of medicines. Prequalification draws from the expertise of some of the
best national regulatory authorities to provide a list of prequalified products that
comply with unified international standards
WHO PQ project
The project was supported by UNAIDS, UNICEF, UNFPA and the World Bank as a concrete contribution to the United Nations
priority goal of addressing widespread diseases in countries with limited access to
quality medicines
WHO PQ project HOW IT WORKSAny manufacturer wishing their medicines to be included in the prequalified products
list are invited to apply. Each manufacturer must present extensive information on the
product (or products) submitted to allow qualified assessment teams to evaluate its
quality, safety and efficacy
WHO PQ project HOW IT WORKS
The standards against which the assessment teams evaluate both the
quality specifications of medicines and the manufacturing sites are based on the
principles and practices agreed by the world’s leading regulatory agencies and adopted by the WHO Expert Committee
on Specification for Pharmaceutical Preparations
WHO PQ project HOW IT WORKS
The assessment teams evaluating the products and manufacturers include experts from some of
the national regulatory authorities of the European Union as well as Canada and Switzerland. These
teams ensure that high quality, international standards are respected. The teams work with
regulators from the developing countries where the medicines will be used to make sure that the process and results are at all times transparent
and trusted by the end-users
Dossier requirementsgeneral
The product dossier should include information on:
1. Details of the product2. Regulatory situation in other
countries3. Active pharmaceutical
ingredient(s)-API
Dossier requirementsgeneral
(3. API continue)
3.1 Properties of the API(s)3.2 Sites of manufacture
3.3 Route of synthesis3.4 Specification
API described in a pharmacopoeia API not described in a
pharmacopoeia3.5 Stability testing
Dossier requirementsgeneral
4. Finished product4.1 Formulation
4.2 Sites of manufacture4.3 Manufacturing procedure
4.4 Specifications for excipients4.5 Specifications for finished product
4.6 Container/closure system(s) and other packaging
Dossier requirementsgeneral
(4. Finished product continue )
4.7 Stability testing4.8 Container labeling
4.9 Product information4.10 Patient information and package
inserts4.11 Justification for any differences to the product in the country or countries
issuing the submitted WHO-type certificate(s)
Dossier requirementsgeneral
5. Interchangeability5.1 Bioequivalence study
5.2 Summary of pharmacology, toxicology* and efficacy of the
product (expert reports)
Bioequivalence dossier requirements for the
prequalification project
Basic guidelines
In vivo Bioequivalence studies areclinical trials in accordance with the
guidelines on:Good Clinical Practice
Good Manufacturing PracticeGood Laboratory Practice
Basic guidelinesAdditional guidance
WHO TRS No. 937, 2006, Annex 9Guidelines for organizations
performing in vivo bioequivalence studies. In: WHO Expert Committee on
Specifications for Pharmaceutical Preparations. Fortieth report. Geneva,
World Health Organization
Current Requirements of WHO for
Prequalification of Vaccines
World Health Organization, HTP/V&B/ATT. LBelgharbi
Source of vaccines, 2004Number of countries
Total = 192 countries
83
61
48
UN agency Procuring Producing
World Health Organization, HTP/V&B/ATT. LBelgharbi
Source of vaccines, 2004Number of countries
Total = 192 countries
83
61
48
UN agency Procuring Producing
43 %43 %43 %
Main source of vaccines for national immunization programmes in 2004
Producing
Procuring
UN agency
32 %32 %32 %
25 %25 %25 %
Prequalificationscheme
100% assured quality
CanadaFrance
SwitzerlandIndonesia
BrazilCuba
GermanyIndiaItaly
AustraliaUnited Kingdom
BelgiumSenegal
JapanRep.Korea
USABulgariaSweden
DenmarkUSA
Assured quality source of vaccine
Assured quality vaccines sourced through WHO prequalifed channel benefit 112 countries
80 countries are at high risk of not fully accessing assured quality vaccines(including 18 producing countries)
• 20 out of 48 producing countries• 65 pre-qualified vaccines produced by 24 manufacturers ( 14 industrialized & 6
developing countries) • NRA assessed in 13 out of 20
countries
The efficient National Vaccine Regulatory Authority should perform the following functions within an efficient Regulatory system:
•Marketing authorization & licensing activities,
•Post marketing: AEFI,•Lot release,•Laboratory access,•Regulatory inspections, and•Authorization & monitoring of Clinical
Trials.
Requirements for PQHighly reliant on NRA oversight, hence relevant NRA is
functional.PSF complete, and info compliant with WHO
requirements and UN tender specificationsResults of testing meet specifications and reflect a
consistent productProduction and control in accordance with WHO
requirementsClinical information relevant to target population and
schedulesLabels, inserts and packaging meet UN tender
specifications Compliance with GMP
Necessary commitments from NRAin order to accept the vaccine
Batch to batch release of the vaccines •Sharing reports of serious adverse events
with a prequalified vaccine•Sharing information on
-critical failure in compliance with GMP-failure to meet specifications-withdrawals or recall of products-suspension or non- renewal of license
Necessary commitments from manufacturer
•Communicate major variations immediately after approval by the NRA. If approval by NRA is not
required, then communicate to WHO before implementation
•Report serious adverse events immediately•Communicate minor variations annually (December)•Provide regular updates of safety profile of the
vaccine/s
Necessary commitments from manufacturer
•Inform on quality complaints if relevant to UN supply
•Inform of withdrawals or recalls of products•Inform suspension or non-renewal of
licenses in countries where the product is marketed
NOTE: Sharing of inspection reports is desirable and may lead to streamlining of WHO site visit
Prequalification: Manufacturers 'shortcomings52% applications submitted by vaccine manufacturers
failed WHO prequalification screening process
Absence of adequate/sufficient clinical data
Absence or insufficient/inadequate stability dataLack of proof of consistency of production
Commercial scale batches unavailable
30 out of 48 producing countries have a functional NRA (%)10 out of 61 procuring countries have a functional NRA (%)
Regulatory oversightNRA ' shortcomings
Evolution: Increasing number of applications and reassessments
0
5
10
15
20
25
30
2000 2001 2002 200 3 2004 2005*
Vaccine applications
Reassessments
Challenges
•More variety of products being assessed•Products of increased complexity (several sites)•More vaccines produced in DC•For products not marketed in Europe, no marketing
authorization in Europe, instead scientific opinion by EMEA. Registration and post- marketing regulatory
functions by receiving country •Registration for export purposes only. Post- marketing
regulatory functions by receiving country•Regulatory responsibility falls increasingly in DC
regulatory authorities
Consultation with Expert Group 2004
In April 2004, a consultation was held in Geneva to get advice from the experts'
committee on different aspects of the current prequalification procedure.
WORLD HEALTH ORGANIZATIONORGANISATION MONDIALE DE LA
SANTE
Procedure for Assessing the Acceptability, In Principle, of Pharmaceutical Products for Purchase by United Nations
Agencies
Annex 4Procedure for assessing the
acceptability, in principle, of quality control laboratories for use by United
Nations agencies
WHO Prequalification Scheme and Local
Medicine Production
Forty-fifth Session of the Regional Committee for the Eastern Mediterranean Region1998
Agenda Item 10
Technical discussions
Regional Self Sufficiency in Vaccine and Drug production
Self sufficiency in the production of essential drugs and vaccines faces considerable challenges.
Despite commitments to develop local production within the
Region, production volume in most facilities does not meet
national needs.
These guiding principles include the following:
Local production is an important component of national drug and vaccines policies and is one of the strategies for achieving equity in access to essential
drugs and vaccines.Quality is the leading priority in relation to decision-
makingAdvancing technology and changing global trade
arrangements have created a new reality which countries and manufacturers have to consider
Governments are responsible for creating an enabling environment that strengthens local
pharmaceutical and vaccine production industries.
Local State Production
An approach for Cost Containment
Vaccine Self-sufficiency in EMR
Strategy and action planbased upon a draft strategy paper
EMRO Strategy for Vaccine SelfEMRO Strategy for Vaccine SelfEMRO Strategy for Vaccine Self---sufficiencysufficiencysufficiency
The strategic goal
All the eligible persons in the member states of EMR have ensured access to
existing and new quality vaccines in accordance with the national
immunization schedules through nationally and/or regionally produced
vaccines.
EMRO Strategy for Vaccine SelfEMRO Strategy for Vaccine SelfEMRO Strategy for Vaccine Self---sufficiencysufficiencysufficiency
Fifth Strategic Objective
Commitment by non-vaccine producing countries
Apart from ensuring the supply of existing and new vaccines to their eligible populations it is also important for these countries to formally
commit in advance their markets to vaccine producers in the region. Without this
commitment any desire or drive to self-
sufficiency would remain a dream.
EMRO Strategy for Vaccine SelfEMRO Strategy for Vaccine SelfEMRO Strategy for Vaccine Self---sufficiencysufficiencysufficiency
Sixth Strategic Objective
Achieving WHO-prequalification status
Prequalification can act as a major booster for the producers in the region. This would not only bring credibility but would also act as a major stimulant for
increasing the production capacity, mobilizing investments and acting as
suppliers even beyond the region, after having met the regional needs.
Recommendations
(aDeveloping countries should develop clear national policies for local production
of essential medicines wherever appropriate and feasible;
(bLocal drug industries should give more attention to producing essential drugs;
and
(cCollaboration between WHO and developing countries should include
technical support for prequalification of locally produced medicines and vaccines
Thank You