I[COLOR="#0000CD"][b][b]CH Q10:
The document takes a number of key elements from ICH Q10 on “Pharmaceutical Quality Systems” and cross-references this a number of times. Note – ICH Q10 was planned to become a new Annex 21 of EU GMP but for some unknown reason this has been moved (along with the Annex 20 on Risk Management) to a new Part 3 of GMP.
Pharmaceutical Quality System (Clauses 1.1 – 1.7): This is the major change in this chapter
Good Manufacturing Practice (1.8 ): No major change.
Quality Control (1.9): No major change.
Product Quality Review (1.10 – 1.11): No major change.
Quality Risk Management (1.12 – 1.13): No major change.
Pharmaceutical Quality System (Clauses 1.1 – 1.7):
Returning to this section, this is where the major changes are. Most of the requirements of what was stated in the previous Chapter’s requirements for “Quality Assurance” have been kept, but in these 6 new clauses there is greater depth of coverage of what a Pharmaceutical Quality Management System is. The major changes include:
Enhancing the importance of considering GMP not only at the manufacturing stage but also during development, technology transfer and product discontinuation (clause 1.2). This follows the spirit of ICH Q10.
The first mention of continual improvement of the system (clause 1.2). Traditionally GMP has not been an active promoter of continual improvement – now it is!
A greater emphasis of process knowledge (1.4 ii), process performance (1.4 viii) and process monitoring (1.4 ix). This is in line with ISO 9001 principles – which have a strong emphasis of monitoring and improving all processes of the Quality Management System.
A stronger emphasis on control of suppliers, the supply chain and all outsourced activities (1.4 vi and vii). This is in line with the regulators concern over the whole supply chain.
Another mention of continual improvement (1.4 xii) can also be seen.
Improved coverage of evaluation of changes both before they are taken and afterwards (1.4 xiii and xiv). Note – there is still no real depth of coverage of a “Change Control System” in EU GMP yet all firms have Change Control Systems.
The first mention of Root-Cause Analysis following problems (1.4 xv). In this section you also see the first mention in EU GMP of Human Error and CAPA. These three terms have never been mentioned in EU GMP before.
An enhanced role for Senior Management (1.5). Here you see that Senior Management (and not the QA Manager) are responsible for the QMS as well as defining roles and responsibilities and ensuring these are defined, communicated and implemented throughout the organisation. Of note is that this is the first mention of “communication” in EU GMP and a strong suggestion that the QMS extends to the whole organisation, and not just the GMP areas.
The formal arrival of Management Review (1.6). This is another ISO 9001 principle with Senior Management required to perform regular review of their quality systems, including identification of improvement of products, processes and the whole system.
Finally a Quality Manual is required (1.7). This is also covered in the recently updated EU GMP Chapter 4 on Documentation. Here we get more detail of what is expected within a Quality Manual. This again is an ISO 9001 idea and in this case should include a description of the quality management system as well as management responsibilities. In ISO 9001 this description of the QMS is achieved by describing the processes of the QMS, its scope and the documents that form the QMS.[/b][/b][/color]