Professional Documents
Culture Documents
What is Pharmaceutical
Quality Management System
(QMS)?
A Pharmaceutical Quality Management System (QMS) develops and
ensures quality procedures in various product life cycle stages such as
manufacturing and product testing.
It includes all the critical stages of drug manufacturing, including:
Formulation
Method development
Facilities
Utility system
Equipment
It ensures that the final product is according to customer requirements, as
well as regulatory requirements to which the manufacturer is obliged to
follow. It uses monitoring methods such as Quality Assurance to prevent
quality deviation and emphasize documentation to record all problems
and their solutions.
Applicable Pharmaceutical
QMS Regulations and
Standards
The Quality Management System (QMS) is not a standard of its own. Its
definition, applicability, and practical implementation rely on other
approved standards. It’s the organization’s responsibility to adopt the
relevant standards, which depend on many factors, including geographical
location, product type, and target market.
Some of the most common standards and regulations applicable to the
Pharmaceutical Quality Management System (QMS) are described below.
International Organization for
Standardization (ISO)
The ISO is an international body involved in developing standards in
various industries, including the Pharmaceuticals. The current standard
for Quality Management System (QMS) is ISO 9001:2015, and previously it
was ISO 9001:2005.
The ISO is not involved in the inspection and certification process. Instead,
independent contractors inspect organizations for compliance with ISO
standards.
The ISO’s Committee on Conformity Assessment (CASCO) is the ISO
representative for developing standards for the certification bodies
involved in the ISO certification process.
Current Good Manufacturing Practice
(cGMP)
cGMP is a regulation enforced by the Food and Drug Administration (FDA),
the US federal agency is responsible for safe production of drugs. The
cGMP focuses on the manufacturing process.
The product must be safe for human consumption, with quantity, quality,
and purpose taken into consideration. The output must be free from
contamination, risk, and most importantly, prevent mix-up of one product
with another product.
The FDA inspects its accredited manufacturers for cGMP compliance. If
FDA finds non-compliance with cGMP regulation and serious drug
adulteration, the manufacturer is directed to recall the product. Failure to
follow the subsequent FDA directions can result in seizure, fines, and jail
time.
ICH Guideline Q10 on Pharmaceutical
Quality System
The International Council for Harmonization of Technical Requirements
for Pharmaceuticals for Human Use (ICH) is a non-profit association under
Swiss law. The ICH comprises professionals from both the manufacturing
sector and regulatory bodies.
The ICH consists of many Pharmaceutical guidelines such as:
Validation
Impurities
Risk management
These quality guidelines are designated by the combination of letter Q
and specific numbers, such as Q8, Q9, etc.
The Q10 guideline is for the Pharmaceutical Quality System.
It does not intend to establish separate enforcement for the
pharmaceutical quality systems. Instead, it provides a consolidated
structure for the quality procedures based on established standards,
including:
ISO
cGMP
ICH Q8 Pharmaceutical Development
ICH Q9 Quality Risk Management
21 CFR Part 211
21 CFR are FDA guidelines for cGMP compliance, and 21 CFR Part
211 includes the cGMP requirements for finished Pharmaceuticals.
Areas this regulation covers are the following:
Quality control
Qualification and skills of the personnel involved
Quality buildings and facilities
Ventilation and filtration system
Process equipment
Product labels
Warehouse requirements
21 CFR Part 11 for Electronic Records and
Electronic Signatures
Industrial automation systems have allowed recording process variables
automatically, without human involvement. The automated recording has
the advantage of accuracy and restricts tampering of data.
The 21 CFR Part 11 is a set of rules that describes how electronic records
are developed, maintained, and stored. It describes the ways of
authorizing these documents by the relevant supervisors, alternate to
manual signatures.
Elements of Pharmaceutical
Quality Management System
There are four elements of a Pharmaceutical Quality System. The drug
manufacturer can incorporate these elements as per product life cycle
requirements, and there is no fixed scheme for applying these elements.
The four elements are:
Process performance and product quality monitoring system
Corrective action and preventive action (CAPA) system
Change management system
Management review of process performance and product quality
Process Performance and Product Quality
Monitoring System
The process monitoring system is an integral part of an organization’s
efforts in delivering a quality product. It shows the company’s
commitment to sustained resources and control.
Risk assessment techniques can be used to detect shortcomings in-
process components. Specialized tools and feedback can also be used to
perform analysis on given parameters.
An example could be detecting faults with the inspection system in Blister
Packaging Machines. The inspection system is designed to detect empty
pockets. Sometimes external factors affect the system, such as the
accumulation of dust particles on the camera lens. In this case, the
inspection system can accept all or just some empty blisters.
The inspection system is checked randomly by both production personnel
and the Quality Department to identify faults or malfunctions.
Luckily, a tool like Issue Management Software by SimplerQMS, automates
data collection, routing, and escalation of overdue activities. This makes
the performance and safety monitoring of your products and processes
much easier.
Corrective Action and Preventive Action
(CAPA) System
Corrective Action and Preventive Action (CAPA) is a system for identifying
the causes of the fault and preventing them from recurring in the future.
The CAPA can be applied in case of complaints from both inside and
outside the organization.
The CAPA structure and CAPA form can be different from organization to
organization, but mainly it consists of the following information:
The department where process deficiency is found
Fault detail and its implications
A possible effect of fault on process or product
Corrective Action to remove the problem
Preventive action to prevent recurrence of the fault
Due date to implement the corrective and preventive actions
Next review date to assess the effectiveness of corrective action
See the illustrated CAPA process below.
After necessary Corrective and Preventive actions are applied, the CAPA is
sent again to auditors for approvals. Upon approval, the CAPA is closed,
and the format is made part of the records.
For example, during a routine audit, the Job Description (JD) of one of the
employees was out of date. The auditors initiated CAPA and gave time to
make the JD available in the department. The respective department
contacted the Human Resource (HR) department regarding the JD. When
JD was available, the respective department filled the CAPA by stating the
problem and proposing corrective action to avoid a similar condition in
the future. The CAPA was presented to the auditors for approval. After
approval, the CAPA format was made part of the records presented to
regulatory bodies upon investigation.
The process presented in the example above can easily be automated
with CAPA Management Software. It automates data collection, routing,
follow-ups, notifications, approvals, and escalation of overdue activities
allowing you to manage Corrective and Preventive Actions more
effectively.
Recommended Reading: What is CAPA in the Pharmaceutical Industry?
Change Management System
Different standards such as ISO and ICH promote innovation in existing
processes to increase product quality. Pharmaceutical companies must
have Change Management System to study, monitor, adapt, and approve
the change.
If the change is implemented after regulatory filings, the change in the
respective process or procedure is submitted to the regulatory body for
review and approval, as per the regulations.
For example, the supply chain department proposes to change the
packaging size to reduce logistics costs. The quality department analyzes
the packaging requirement in light of accredited regulatory bodies and
approves the change. The engineering department analyzes the current
equipment and its system to apply the change. After approvals from these
departments supply chain orders the new packaging material size to
implement in a small number of products. When these small quantities of
products are prepared, the supply chain checks for its success and
communicates it to all relevant departments.
After approval from the supply chain, the production department updates
its standard operating procedure (SOP) and communicates it to the
Quality and Engineering department. The change is made official in
change control format, with necessary approvals from the Production,
Quality, and Engineering departments. The change is then reviewed by
higher management to made part of the company’s policy and process.
Fortunately, Change Management Software by SimplerQMS makes the
change management process a whole lot easier. It allows you to
automatically track changes to SOPs, instructions, products, and product
processes. Using the software, you can easily send changes through the
approval process, and ensure that changes are implemented.
Management Review of Process
Performance and Product Quality
Management review is a process of reviewing process and product quality
across various management hierarchy levels to escalate urgent quality
and product problems. The purpose of management review is to propose
improvements in product quality and process.
The management review includes the following:
The commitment made to regulatory bodies
Customer complaints
Nonconformances
CAPA review
Audit findings
Process performance
Any pending matter or follow-up from previous management review
After the management review issues are typically escalated to improve a
specific area of business.