Tag Archive for: GMP

GMP standards for medicinal cannabis: guaranteeing quality in an emerging industry

The medical use of cannabis is gaining increasing recognition and legal approval worldwide, leading to growing demand and increased regulation. In this dynamic environment, Good Manufacturing Practice (GMP) standards are crucial for the production of safe, high-quality products. However, the implementation of GMP standards is a challenge for the medical cannabis industry, as many companies first need to establish the necessary structures and skills. Specialized consulting can make a significant contribution to the efficient implementation of GMP-compliant processes.

GMP standards and their importance in medical cannabis production

GMP standards, implemented by the Food and Drug Administration (FDA) and further developed by the World Health Organization (WHO) and adapted to the global market, are a global quality benchmark for the pharmaceutical industry. These standards require strict specifications for the documentation, control and monitoring of production processes in order to ensure product safety and efficacy [1]. In the medical cannabis industry, these standards are of fundamental importance, as there are no guidelines specifically developed for cannabis production, although cannabis products are also used as medicines and can affect vulnerable patient groups. Instead, reference is made to the general processing of herbal substances [2], which is particularly important in the drying and preparation of plants. GMP ensures that all products are manufactured in a hygienic environment under controlled conditions to avoid contamination and ensure the safety of the final products [3].

Challenges of GMP implementation in the cannabis industry

GMP implementation in cannabis production poses specific challenges. For example, ensuring consistent product quality requires precise control over the entire manufacturing process – from raw material extraction to bottling. Medical cannabis products must have consistent concentrations of active ingredients to ensure therapeutic effects, which requires precise process control and laboratory testing [4]. In many cases, however, companies lack comprehensive knowledge of GMP standards and their specific application to cannabis production.

GMP compliance is complex and requires not only the establishment of suitable processes, but also the training of personnel and the implementation of quality assurance systems. In addition, regulatory requirements vary from country to country and are constantly evolving. Strategic advice can help to overcome specific challenges and ensure ongoing compliance with GMP requirements.

Good manufacturing practice (GMP) in practice: important steps and measures

1. production environment and hygiene: GMP guidelines require a strictly controlled production environment to prevent contamination by microorganisms, heavy metals or pesticides. Cannabis products must not contain any undesirable residues that could impair efficacy or safety [5].

2. quality control and laboratory testing: Each production batch of medicinal cannabis must undergo rigorous testing to confirm the active ingredient content and rule out impurities. These laboratory tests ensure that the final product meets quality standards and that consumers are not exposed to any risks [3].

3. documentation and traceability: GMP compliance requires comprehensive documentation and complete traceability of products in order to be able to act quickly in the event of quality problems or recalls. Every production stage, every test and every release must be documented in detail in order to prove conformity [1].

4. staff training: GMP standards require continuous training and education of employees to ensure that all processes are carried out and documented correctly. For many companies in the cannabis industry, this poses an additional challenge, as specific GMP knowledge is often not sufficiently available in the team [4].

The added value of specialized consulting for GMP-compliant processes

Strict compliance with GMP standards is essential for companies in the medical cannabis industry in order to be successful on international markets and build trust with consumers. However, especially for companies that are new to the market, the implementation of these standards requires considerable organizational and financial effort.

Our consulting expertise supports you in all phases of GMP implementation – from the development of a customized quality management system to employee training and complete documentation. We also offer regular audits and support in preparing for inspections to ensure continuous GMP compliance.

Conclusion: GMP as a guarantee of safety and trust in the medical cannabis industry

The requirements for medical cannabis are constantly increasing, as patient safety is a top priority and regulatory requirements are growing. The implementation and maintenance of GMP standards are a basic requirement for any company that wants to establish itself in this market in the long term.

We are happy to support you in achieving GMP compliance cost-efficiently and sustainably, strengthening your market position and guaranteeing the safety of your products. Get ahead and in touch with us – info@expertsinstitut.de

Sources

1. Good Manufacturing Practices for Pharmaceutical Products: Main Principles. World Health Organization (WHO).

2. cannabis Q&A for the public

3. Quality Standards and Practices in the Medical Cannabis Industry. International Journal of Drug Policy.

4. WHO Guidelines on Good Agricultural and Collection Practices (GACP) for Medicinal Plants. WHO, 2003.

5. Good Distribution Practice for Medical Cannabis Products. European Commission, 2017.

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GxP audits: How important are they and how are they conducted?

In the highly regulated pharmaceutical industry, audits are more than just a control mechanism – they are an indispensable tool for ensuring the quality and compliance of processes. Audits play a key role in ensuring that companies adhere to the strict requirements of Good Manufacturing Practice (GMP) and other GxP standards. The aim is not only to identify errors, but also to continuously improve processes and eliminate weaknesses before they lead to errors or quality problems. The role of audits in quality management can therefore not be overestimated. They help to meet regulatory requirements and at the same time strengthen the trust of customers and authorities in the company.

Below you will find out what a GxP audit is, why it is so important for companies in regulated industries and how it can be carried out optimally.

What is a GxP audit?

An audit is a systematic, independent and documented review that serves to determine whether activities and results meet the planned requirements. So much for the theory.

In the GxP area, audits are particularly important in practice, as they ensure that all processes actually meet the strict requirements of GMP, GLP and GCP standards. These audits not only check compliance with regulations, but also whether processes are used for continuous improvement and risk reduction and actually make this contribution.

Why are audits in the GxP area so important?

Audits fulfill a central function in the so-called Pharmaceutical Quality System (PQS) and offer many advantages that are important for the entire industry:

  • Audits guarantee that companies comply with and implement the legal and regulatory requirements in such a way that the medicines produced are of truly impeccable quality and also safe.
  • Audits make it possible to identify potential errors in operations and production at an early stage so that measures can be taken to minimize risks. This prevents critical errors or weaknesses in the production process from leading to serious problems and questionable medicines from reaching the market and patients.
  • Audits offer the opportunity to evaluate existing processes and identify optimization potential. In this way, companies can increase their efficiency and improve quality at the same time.
  • Regular audits strengthen the trust of customers, partners and regulatory authorities. A well-documented and executed audit shows that the company is able to critically scrutinize itself in order to reliably deliver high-quality products to the market.

The audit process: step by step

An audit in the GxP area follows a structured procedure that enables the auditor to thoroughly examine the processes in the company. Typically, an audit consists of six main phases:

  1. Planning: Audit preparation is crucial for success. The parties involved must ensure that all relevant people and documents are available. Thorough planning ensures a smooth process.
  2. The initial meeting: In this step, the auditors and the representatives of the company to be audited meet at the start of the audit. The audit plan or the audit agenda is discussed again. Questions are also clarified here and expectations are defined if they have not already been clearly understood before the audit.
  3. Conducting the audit: The auditor checks the company’s premises, machines, documents and processes. Interviews with employees also take place during this phase in order to assess the practical implementation of the processes.
  4. The final meeting: At the end of the audit, the results are summarized. This is where we discuss what worked well and where there is room for improvement.
  5. The audit report: The auditor prepares a detailed report documenting the results of the audit. This report also contains recommendations to help the company eliminate weaknesses and further improve processes.
  6. Follow-up of the audit results: After the audit, follow-up is essential to ensure that the recommended measures have been implemented. This includes documenting the corrections and, if necessary, rechecks to ensure the sustainability of the improvements.

Preparing the audited company for a GxP audit: how to succeed

Thorough preparation is the key to a successful audit. Companies should ensure that their documents are complete and up-to-date and that their employees are aware of the requirements of the audit. Employee training plays a central role here, as a well-prepared team helps to ensure that the audit runs smoothly and possible deficiencies can be identified at an early stage.

Tips for audit preparation:

  • Review all important documents, including SOPs (standard operating procedures), batch documentation and qualification documents
  • If possible, carry out internal mock audits in advance to identify weaknesses in advance
  • Bring your team up to speed on regulatory requirements and audit expectations

Successful audit practice: the key to success

A successful audit requires careful preparation, a clear structure and detailed follow-up. Cooperation between the auditor and the audited company is of great importance in order to develop a common understanding of the requirements and expectations. This not only promotes compliance, but also the continuous improvement of processes. Companies that integrate regular audits into their business processes improve their quality assurance and reduce the risk of production errors or non-compliance with regulations.

Conclusion: Audits as the key to quality assurance

Audits are an indispensable part of quality management in the GxP sector. They not only help to ensure compliance with regulations, but also promote the quality and safety of products. Thorough preparation and the selection of experienced auditors are crucial to the success of an audit.

At Experts Institut, we not only offer training courses for auditors, but are also happy to support you in ensuring your compliance and continuously improving your processes. We can do “audits”. Contact us at info@expertsinstitut.de

Would you like to find out more?

Listen to our podcast episode “Audits in the pharmaceutical industry”, in which we examine the importance and challenges of audits in detail: https://podcasters.spotify.com/pod/show/experts-insights/episodes/Audits-in-der-Pharmaindustrie-e2of577

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GMP Guidance for Artificial Intelligence (AI), Machine Learning (ML) and Digital Transformation: How it Finally Begins to Enter the EU GMP Guide

The Now: Gaping Holes

When sifting through today’s status of the EU GMP Guide, it does not take an expert to see that there are gaping holes on topics of engineering, management of computerized systems, data integrity, digitalization and application of artificial intelligence.

Not that the guide has nothing to say to some of these areas. At least by means of implication the guide says lots of things between the lines. This very “in-between” is what gives pharmaceutical manufacturers quite a headache when facing governmental inspections.

The issue is that what it has to say does not cover what’s actually out there. And “by implication” is simply not a good advisor for the industry. It may be good enough for an inspector to set up interpretive requirements and for giving industry a hard time. But for a company it is simply not practicable when a text is elusive.

Although we have best practices like ISPE GAMP5 or other guidance somewhere out in the GxP universe, we would like to know from our most relevant guide-the EU GMP Guide-what is required. And this very guide has been doing a rather horrible job to provide the input industry needs (it seems not surprising that some EU countries struggle massively to keep life sciences and pharmaceuticals on their territory).

A New Hope

A new hope may be on the horizon as we have been expecting a revised version of Annex 11. There-so the concept paper tells us-we will receive a text that will address words such as artificial intelligence, clouds, and even digital transformation. One might wonder whether it is worth holding our breath for the release of the new Annex 11, as high hopes have been shown to greatly disappoint before. One might remember Annex 21 or interpretive documents from local supervizing authorities, that in the end have not been helpful for real life at all.

However, in this case it may be different. Can we guess some consequences from this next generation Annex 11?

GMP

GMP Data Integrity Finally Takes Center Stage

Although some would passionately disagree with me on this, the EU GMP guide has virtually lacked clarity on data integrity for decades. It was the US FDA who had to essentially teach us in Europe what Data Integrity is and why this is important. Without them we would still think that Good Documentation Practices and Validation of Spreadsheets is all it takes.

I love how every EU member state GMP inspector knows exactly what is necessary in terms of data integrity-only with next to no express textual basis for it in the EU GMP guide. I mean sure: evey company has by now heard of data integrity, letalone has received inspections that dealt with it. And yes, we were told after the fact that the GMP guide has “always meant” data integrity in various little phrases of the guide. But that seemed a bit of a crutch to assure the colleagues from US FDA that in Europe data integrity is something we “totally want and require!”

Point taken, it is true that in the Annex 11 we had such wording in some spots. And now the EU guide will finally take into consideration the fuller importance of data integrity-at least for computerized systems. One can tell that the EU grows more towards considering guidance from for example WHO or PIC/S.

The consequences will be that audit trails and audit trail review requirements will be clarified and likely deepend. More work. The bar for what is “basic” will be raised.

The same will happen for archiving, backups, and retrieval requirements for archived data. Companies will unlikely be able to keep playing the low-key game in the archiving area.

Management of Clouds will be a Topic

This will be upgraded, or actually decently considered in the new Annex 11. And here I must say that this is positive improvement. The GMP guide has been pretty much blind to this for quite some time now. It will be a reasonable change. It will be interesting to see how block-chain systems will be treated under the new Annex 11.

And I certainly will be interested to see how cloud hosts seriously validate and qualify their systems, software, and infrastructure. The hunsh is: this is going to cause trouble for some service providers. My recommendation to cloud providers who have pharma-clients: Get ready for it now, or You will be out of business before You know it.

If this enters Annex 11 it could mean:

– cloud services must qualify their infrastructure according to GMP.

– they must validate their software fully in line with GMP as well.

This essentially would require a quality-oriented quality management system (and no, ISO9001 would not suffice, not the slightest chance for anyone who wants to take this seriously).

GMP for Artificial Intelligence (AI) and Machine Learning (ML) will Hatch

We must be honest here: it might not be a whole lot of guidance what we will receive from the revised Annex 11:

The primary focus should be on the relevance, adequacy and integrity of the data used to test these models with, and on the results (metrics) from such testing, rather that on the process of selecting, training and optimizing the models.

https://www.ema.europa.eu/en/documents/regulatory-procedural-guideline/concept-paper-revision-annex-11-guidelines-good-manufacturing-practice-medicinal-products-computerised-systems_en.pdf

Though this quote from the concept paper is as elusive as sand running through one’s fingers, it does give us a tiny insight into what will be important to a regulator or a GMP-inspector: data (and their quality) used to feed AI models.

One of the biggest questions is: How in the world do we validate AI and ML? Will AI or ML need to be validated according to the typical V-model? In reality this seems almost impssible, since any software code change would required re-validation. And code changes might have to be expected, especially with machine learning. My assupmtion is that we will not receive much help here form the new Annex 11. Industry will be thrown back on non-governmental best practice guidance-as is often the case.

“No New Requirements”

It must be acknowledged that some of what we will find in the revised Annex 11 will likely be clarification and nailing down of requirements that were logical consequences from what is in the current version of the Annex. Yet, we will also find more work, new requirements.

For each company a careful gap assessment will be in order, and for those who have gotten away with mediocre management of electronic systems it will be time to act and invest in modernization.

Needless to say, that I am already looking forward to the next years at Experts Institut, when those projects will continue to fill our work schedules. It is a great challenge!

GMP Challenges for Small Pharmaceutical Businesses

I encourage representatives of small businesses – smaller pharmaceutical entities – to comment and to give feedback once the draft to the new Annex 11 is out. Often it is the larger pharmaceutical businesses that drive or influence what best practice is or what those texts may contain. A consequence can be that the requirements push smaller companies off the cliff of financial and infrastructural fesability. This does not need to be so. But small businesses must take a bit of a stand here. Take the chances You get, that is my recommendation. Digitalization and the use of AI and ML are unstoppable because neither society and nor the economy will not stop it. This is coming at the industry real fast. And it will likely make or break smaller business in the near future. So – get ahead with it!

Experts Institute can help!

Need help with GMP-Digitalization projects and AI-validation concepts? Contact us. Management consultancy GMP, GXP & Business Solutions | Experts Institut (experts-institut.com).

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Crossing Cultures in Audits and Inspections

Today the world, with its regulated industry, is strongly globalized. The cultural diversity of a company’s staff can be huge, reflecting different cultures from around the world. This is one reason why many would assume that the entire world can be talked to, related to, and understood quite readily. It is part of everyday work for many after all-or so we think.

In the area of audits and inspections, crossing cultures happens all the time. Different cultures bring different perspectives, which can influence how audits are perceived and conducted. Where supply chains are globalized, trans-national and trans-continental audits and inspections are mandatory and pretty much normal in many company and regulatory settings. Understanding the nuances of each culture involved is essential for effective communication and successful outcomes.

True Multiculturalism and Cultural Limits

This poses a problem though: we learn to communicate, read, and perceive in our birth culture. And even if a society is highly diverse, we are still product of a cultural framework that is discrete-in other words, that has boundaries. It is simply impossible for one person to really become multicultural-ourlifespan is just not large enough. You may be the child of a double or third culture set of parents, but true multiculturalism in a single individual is virtually impossible.

So as we are controlled by our birth culture, we do not learn how to properly navigate in foreign cultural contexts (and globalization does not do away with this at all). We may think we know what is going on around us when we engage people from other host cultures, but we really do not. Even in a seasoned friendship with someone from another country, there will still be a vast degree of ignorance in understanding the other person. We believe we know and understand. But we miss most of it in reality. We continue to filter everything we experience, see, hear and judge through what we believe is normal, and our frame of reference is our birth culture. And we cannot stop doing it because we are not even aware of it.

The Impact of Culture on Audits and Inspections

And now it gets interesting: This problem includes audit and inspection situations!
Good auditing is more than knowing compliance requirements, audit methodology, and a work experience of 100+ or even 1000+ audits.

Culture is so powerful that it controls everything we think, say and do. And what we expect of others. In an audit situation (also in GMP inspections), this routinely produces misunderstandings. And many of them are never corrected, simply because neither the auditor nor the auditee is aware of them.

From document reviews, an auditor may conclude that a company is falsifying records, when the truth is though that what the auditor saw has nothing to do with cheating at all.

An auditor may think the auditee is trying to avoid saying the truth about a given audit question or subject, but there is no intent of this in the conversation at all. But the auditor is blind to this.

As a result of examples like these, auditors will put their impressions into the report, in a coded form of course, but it will color all parts of the report and the perception of GMP deficiencies-even the judgment on severeness.

If an auditor is not aware of what is missed and where the personal perception of things is going astray, then such an auditor must improve. The objectiveness of the report will suffer, and the picture that is brought home is greatly inaccurate. We do a disservice to the auditee and to our own sending unit. And frankly, to ourselves…

This plays out even more drastically in audits of suppliers or service providers where no GMP or GxP quality system is available. Such cultural ignorance can make or break the business relationship altogether.

How can you improve?

  • Stop thinking that cultural differences are easy to figure out. You cannot guess them. You need extra training for this.
  • Understand that cultural differences have little to do with differing food preferences or how a business card must be presented.
  • Respect that standards-even GMP-can be lived effectively in different ways.
  • Open to the truth that you do not know everything best.

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GMP reagent management: Many unspoken rules?

So inconspicuous and yet so important, especially from today’s perspective: Section 6.19 of Chapter 6 of the EU GMP guidelines once again significantly increased the effort required to carry out analytical tests:

6.19 Special attention should be given to the quality of laboratory reagents, solutions, glassware, reference standards and culture media. They should be prepared and controlled in accordance with written procedures. The level of controls should be commensurate to their use and to the available stability data.

Miniature manufacturing instructions

If strictly interpreted, this means that a miniature manufacturing instruction and therefore also a specification should be created for each affected article – and of course all of this should be integrated into the usual document control system. No, this has not yet been an explicit requirement to this extent, even if it was tacitly expected in some inspections.

But that’s not all: in order to determine whether and how often, for example, a reagent itself must be tested analytically, stability data must now be used(!) – in a strictly literal interpretation.

Pharmacopoeia descriptions

There are plenty of unanswered questions: Can pharmacopoeia descriptions (if available) replace written manufacturing instructions for reagents? Do expiry dates or re-test data from reagent suppliers also count as stability data in the broadest sense (and this is still not clear)? If I change the manufacturer of an initial reagent, do I have to document everything via a change control procedure, i.e. is this a ‘significant’ change?

No footnotes, no Q&A document from the EMA – until now. However, the consequence of non-compliance with section 6.19 is clear: in extreme cases, analysis results may be called into question and retesting of already marketed products may be necessary as a follow-up measure. Where results were included in the assessment of critical incidents (e.g. OOS events), a reassessment may also be appropriate.

Our recommendation: The legislator has obviously deliberately made long-standing unspoken requirements much clearer. If your lab has any gaps here, don’t put it off, but make an action plan now to fix it! Definitely better than only reacting when the child has fallen into the (GMP inspection) well…

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Sensible limit values for process capability

The calculation of the process capability in the form of the process capability index (Ppk or Cpk) sets the scatter of the individual results and the position of the mean value in relation to the specification limits. The higher the process capability index, the further away the individual results are from the specification limits.

Calculation of the process capability index:

The following parameters are included in the calculation of the process capability index:

  • Mean value (μ)
  • Standard deviation of the mean value (σ)
  • Upper and lower specification limit (OSG and USG)

The first step is to calculate the process capability indices “Cpo” and “Cpu” for the upper and lower specification limits:

Cpo = (OSG – μ)/(3σ) OSG = upper specification limit

Cpu = (μ – USG)/(3σ) USG = lower specification limit

Cpk = min(Cpo, Cpu)

In a second step, the lower value (Cpk = smallest process capability value) of the two values is selected:

The calculation of meaningful Cpk values is only possible from 25 – 30 individual values.

Sample calculation:

Investigated quality characteristic: content of a medicinal product

Specification limits: 95 – 105 mg

Average value: 98 mg

Standard deviation: 0.5 mg

Cpo = (105 mg – 98 mg)/(3×0.5 mg) = 4.7

Cpu = (98 mg – 95 mg)/( 3×0.5 mg) = 2.0

Cpk = min(Cpo, Cpu) = 2.0

But what do the Cpk values obtained mean?

Cpk = 1.00

If 1 million units are checked, 2699 faulty units would be found. The distance of the mean value to the next specification limit corresponds to 3 times the standard deviation (3σ) of the values.

Cpk = 1.33

If 1 million units are checked, 66 faulty units would be found. The distance of the mean value to the next specification limit corresponds to 4 times the standard deviation (4σ) of the values.

Cpk = 1.67

If 1 million units are checked, no faulty units would be found. The distance of the mean value to the next specification limit corresponds to 5 times the standard deviation (5σ) of the values.

Cpk = 2.00

If 1 million units are checked, no faulty units would be found. The distance of the mean value to the next specification limit corresponds to 6 times the standard deviation (6σ) of the values.

The limit values selected for the CpK value should be determined on a risk basis. This means that the more critical a quality characteristic is, the higher the acceptance criterion for the CpK value should be.

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