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Module 1 - Medicinal Products

1. GMP01

1.1 Module 1 Introduction to GMP 1 - Medicinal Products

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1.2 About this module

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1.3 Objectives

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1.4 Definitions

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1.5 Quick quiz 1

(Matching Drag-and-Drop, 10 points, unlimited attempts permitted)

Correct Choice

Good Laboratory Practice GLP

Good Automated Manufacturing Practice GAMP

Current Good manufacturing Practice cGMP

A casual term used as an abstract from a GxP


specific quality guideline

Feedback when correct:

That's right! Remember, the Quick Quiz is not part of your final score. Use these questions to
check your knowledge before attempting the Final Assessment.

Feedback when incorrect:

You did not select the correct response. Remember, the Quick Quiz is not part of your final score.
Use these questions to check your knowledge before attempting the Final Assessment.

Notes:

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Correct (Slide Layer)

Incorrect (Slide Layer)

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Try Again (Slide Layer)

1.6 Who regulates GMP rules?

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1.7 Risk based approach

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1.8 What is GMP?

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1.9 What is GMP cont...

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1.10 Overview of quality assurance

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1.11 Manufacturing

Production and control operations should be clearly specified

cGMP compliant procedures should be made for the manufacture, supply,


and use of the correct starting and packaging materials

All necessary controls on intermediate products, and any other in-process


controls and validations must be carried out

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1.12 Finished product

The finished product should be correctly processed and checked, according


to the defined procedures

Products should not be sold or supplied before an authorized person has


certified that each production batch has appropriate quality

Products should be stored, distributed and subsequently handled so that


quality is maintained throughout their shelf life

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1.13 Self-inspection

There should be a procedure for self-inspection which regularly appraises


the effectiveness and applicability of the quality assurance system

1.14 Responsibilities

Managerial responsibilities should be clearly specified and documented

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1.15 What does the QC department do?

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1.16 Foundations of quality control

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Foundations (Slide Layer)

Procedures (Slide Layer)

Testing (Slide Layer)

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Starting materials (Slide Layer)

Records (Slide Layer)

Finished products (Slide Layer)

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Release (Slide Layer)

Sampling (Slide Layer)

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1.17 GMP and the law

Notes:

1.18 GMP code

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1.19 Quality management

(click on each tab to see relevant information)

Intro (Slide Layer)

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International standards (Slide Layer)

Governance (Slide Layer)

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1.20 Product quality review

Notes:

1.21 Quality risk management

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1.22 Quick quiz 2

(Multiple Choice, 10 points, 1 attempt permitted)

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Correct Choice

A) There were a large number of QC samples awaiting analysis, some dated from
previous weeks.

B) The QA manager had a large pile of documents needing to be approved and


signed.

C) The receiving area in the warehouse was crowded with goods, waiting to be
booked in.

X D) All of the above.

E) None of the above.

Feedback when correct:

That's right! All of these situations may indicate inadequate staffing levels. They may also
indicate a need to review procedures for efficiency!

Feedback when incorrect:

The correct answer was 'D) all of the above'. All of these situations may indicate inadequate
staffing levels. They may also indicate a need to review procedures for efficiency!

Notes:

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Correct (Slide Layer)

Incorrect (Slide Layer)

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1.23 Personnel

QA systems and adherence to GMP guidelines relies exclusively on people

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1.24 Having the right number of personnel

The GMP guidelines recognize how critical people are to ensuring product
quality.

To meet GMP requirements, it's essential to have:

the right number of people, and

that they have the right qualifications and experience to do the job

To meet these requirements it's essential that what 'right' means has
been identified for every function and process.

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1.25 Personnel training

The GMP guidelines recognize that training is very important.

During an audit, an auditor might ask to see:

competency matrices – identifying the skills and training required for each
role in the organization

training records to show when someone was trained and what they were
trained on

These records must be kept for everyone who works in a GMP area,
including:

contractors

cleaners

supplier’s representatives who visit frequently, such as equipment service


engineers

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1.26 Contractors

Contractors, such as salespeople and cleaners, are a common source of


non-compliance

It is critical that contracting companies supply only GMP trained


personnel to work in production areas

Untrained staff, filling in for someone who is away, will not understand
how much they can impact product quality

Example:

A piping contractor, installing a filter housing, unknowingly left waste


materials in the water system. The system supplied sterile water for the
manufacture of injectable drugs. However, the water system would
contain an on-line TOC or a conductivity meter to detect and dump un-
sterile water before it gets into the distribution loop. Also, QC tests on the
water would detect such a problem before any drugs were released.

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1.27 The GMP essentials

Because personnel are such a critical part of GMP, the GMP guidelines
specify that:

all staff must have the education, experience, and training to perform
their duties

documentary evidence of this must be maintained, including resumes,


professional qualifications, and training records

an organizational chart is mandatory (and can be subject to auditing)

the responsibilities of each position must be defined and documented

the head of production and quality control must be independent from


each other

good personal hygiene is critical – staff must be trained and equipped to


ensure good personal hygiene

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1.28 Good hygiene

It is critical that staff reduce the risk of introducing infections and bacteria
into the area where products are being made. This includes:

reporting open sores or any illness to their supervisor

appropriate washing of their hands

no eating, drinking, chewing or smoking, and no storage of food, drink,


smoking materials or personal medication in production and storage
areas

all personnel entering the manufacturing areas should wear clothing


appropriate for the area and the operations to be carried out

unhygienic practices within the manufacturing areas or other areas where


product may be adversely affected should be forbidden

Notes:

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1.29 Manufacturing equipment

Ensure manufacturing equipment:

is designed, located, and maintained to suit its intended use

is designed so that it can be easily and thoroughly cleaned

has procedures for how and when to clean each piece of equipment that
can impact product quality

has procedures that clearly state who is responsible for the cleaning and
have cleaning records

Notes:

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1.30 Design

The GMP guidelines ensure that manufacturing facilities are designed to


minimize product contamination and mix-ups.

For example:

Using coved ceilings, floors and corners within manufacturing areas


minimizes debris and thus bacterial accumulation

Machines should be located to allow easy access for regular maintenance

Dedicated lines or facilities i.e. physical separation, should be used when


manufacturing products that have high cross-contamination potential

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1.31 Equipment placement

Example:

In one company, the maintenance schedule for a piece of production


equipment required the oil to be changed and 55 sensor points to be
checked every 3 months.

During an audit, the auditor discovered that this was only being done
during the annual shutdown period.

Why?

The machine had been installed very close to the wall. The maintenance
engineer could only access the back of the machine when it was moved
away from the wall. This could only be done during the annual shutdown,
when a mobile crane was available to lift the machine.

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1.32 Premises design

Modern warehouses at commercial manufacturing sites are totally


automated and their status and location are controlled by an enterprise
management system. A modern warehouse is divided into a receiving
area and a storage area in which there are specific areas to store rejected,
recalled or returned materials or products. Optimally, rejected product
would be kept in a caged area.

Again, the aim is to prevent contamination and mix-ups. It would be very


easy for a batch of recalled products to be accidentally shipped out to
customers if the recalled products were not kept physically separate from
the final products in the warehouse.

QC labs are separate from production areas.

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1.33 Facilities

The facilities should be designed and equipped to prevent entry of pests or


animals

Steps should be taken to prevent entry of unauthorized personnel

Where special storage conditions are required (e.g., temperature,


humidity) these conditions should be provided, checked and monitored
and also validated

(e.g., temperature mapping) on a periodic basis

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1.34 Premises and equipment

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1.35 Data collecting equipment

The GMP guidelines require equipment to be fit for purpose. If the


weighing step is critical to product quality, then equipment should be used
that will ensure an appropriate level of accuracy.

A good practice is to display the usable range on all scales. As a rule of


thumb, the minimum weight that the scale interval can introduce should
be less than a 0.5% error.

This means if a scale can weigh up to 1000g and the scale interval is to
0.1g, then the minimum of 20g may be weighed on that scale.

If the scale rounded to say 0.5g intervals, then the minimum permissible
weight should be 100g.

The above is only a 'rule of thumb' - all scales should be validated for their
intended purpose.

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1.36 Scenario

Notes:

1.37 Quick quiz 3

(Multiple Choice, 10 points, 1 attempt permitted)

Correct Choice

A) She should have repeated the measurements three times and calculated the
average to ensure the result was accurate.

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X B) She should have requested scales that had a range from 0-1kg and displayed
x.xg.

C) She should have held 10 products to make the weight more appropriate for the
scale, dividing the weight difference by 10 to calculate the final weight of each
product.

Feedback when correct:

That's right! You selected the correct response.

Feedback when incorrect:

The correct answer is B. She should have requested scales that had a range from 0-1 kg and
displayed x.x g.

Correct (Slide Layer)

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Incorrect (Slide Layer)

1.38 Documentation

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Documentation (Slide Layer)

Documentation types (Slide Layer)

Equipment logbooks (Slide Layer)

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Document control (Slide Layer)

Things that go wrong with documents (Slide Layer)

Document essentials (Slide Layer)

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1.39 Quick quiz 4

(Multiple Choice, 10 points, 1 attempt permitted)

Correct Choice

A) Development and production

B) Production and batch release

C) Distribution and development

X D) All of the above

Feedback when correct:

That's right! You selected the correct response

Feedback when incorrect:

The correct answer is D. Pharmaceutical manufacturers must have documented quality


procedures covering all of these processes.

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Correct (Slide Layer)

Incorrect (Slide Layer)

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1.40 Production

Intro (Slide Layer)

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GMP (Slide Layer)

Containment (Slide Layer)

Procedures (Slide Layer)

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Personnel (Slide Layer)

Labeling (Slide Layer)

Process (Slide Layer)

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1.41 Quality control

intro (Slide Layer)

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QC is not confined to a lab (Slide Layer)

QC is at the core of every process (Slide Layer)

QC from start to finish (Slide Layer)

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1.42 Contract manufacture

Notes:

1.43 Responsibilities – contract giver

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1.44 Responsibilities – contract acceptor

The contract acceptor must have adequate premises and equipment,


knowledge and experience, and competent personnel to carry out
satisfactorily the work ordered by the contract giver.

The contract acceptor must ensure that all products or materials delivered
are suitable for their intended purpose.

The contract acceptor must not pass to a third party any of the work
entrusted under the contract without the contract giver’s prior evaluation
and approval of the arrangements.

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1.45 Responsibilities

There must be a designated person responsible for handling the


complaints and deciding the measures to be taken.

Notes:

1.46 Defined procedures

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1.47 Investigation

If a product defect is discovered or suspected in a batch, other batches


must be checked in order to determine whether they were also affected.

In particular, other batches which may contain reworks of a defective


batch must be investigated.

1.48 Record keeping

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1.49 Traceability

Distribution records must:

be readily available

contain sufficient information on wholesalers and directly supplied


customers, including those for exported products and medical samples

1.50 Product reconciliation after a recall

1.51 Quick quiz 5

(Multiple Choice, 10 points, 1 attempt permitted)

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Correct Choice

X A) Recorded

B) Ignored unless there is a trend

C) Passed onto the appropriate department

D) Recalled immediately

Feedback when correct:

That's right! All product complaints must be recorded and investigated thoroughly.

Feedback when incorrect:

The correct answer is A. All product complaints must be recorded and investigated thoroughly.

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Correct (Slide Layer)

Incorrect (Slide Layer)

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1.52 Self-inspection

Notes:

1.53 The 10 Golden Rules

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Facility design (Slide Layer)

Validations (Slide Layer)

Procedures (Slide Layer)

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Training and development (Slide Layer)

Good record keeping (Slide Layer)

Responsibilties (Slide Layer)

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Hygiene (Slide Layer)

Maintenance (Slide Layer)

Quality (Slide Layer)

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Audits (Slide Layer)

The 10 golden rules of GMP (Slide Layer)

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1.54 Case study - hygiene & cleaning

1.55 Things that go wrong! - example one

Notes:

Despite the emphasis, strict procedures and training, things


sometime go wrong. These can be predictable, such as things that
go wrong as a result of failing to follow written procedures, or
unpredictable, as a result of contamination from an unexpected
source.

However, no matter what the root cause, such incidents are


avoidable. In the examples below the actions needed to avoid things
going wrong should be self-evident:

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Example 1:

Frequent problems of contamination in a clean room by an organism


normally found in water and soil (dirt or earth). On investigation there
were three contributing factors to the root cause:
a.Operators walking out of the clean room wearing their
dedicated shoes and then walking back into the clean room
without cleaning the shoes or putting on clean overshoes
b.Inadequate clean up following frequent spillages
c.Inadequate and infrequent clean up of condensate from a
heat exchanger dripping onto the clean room floor

Lessons learned:

• Dedicated shoes are dedicated to a specific clean room suite


and to a specific operator. Operators need to understand
why they are wearing them and how contamination can be
spread on the feet!
• Spillage and leakage must be dealt with immediately, not just
at the end of the shift, or the day, or the week! This is not
routine cleaning.

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1.56 Things that go wrong! - example two

Notes:

Example 2:

Following a fire alarm in the factory, the clean room operators assembled at the
fire assembly point in the parking lot still wearing their clean room gowns, since
the fire regulations require that everyone evacuates the building immediately and
does not stop for any reason! The gowns were not changed when the operators
returned to work because the gowning procedure only required a daily gown
change and did not cover fire evacuation. This resulted in high levels of
microbial contamination, which took a lot of cleaning and monitoring before it was
cleared. This demonstrated a lack of awareness of the purpose of the gowning.

Lesson learned:

Awareness of the concepts of hygiene and gowning and the problems that bad
practices can cause, is as important as completing the “how to” training.

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1.57 Things that go wrong! - example three

Notes:

Example 3:

A clean room operator, involved in the manufacture of biological drug substances,


was also the owner of a small farm and a small dairy herd. He would come to
work each day after milking the cows. During the environmental monitoring of
the manufacturing areas, a resistant and unusual microorganism was found in
high numbers.

On investigation it was found that this organism is normally found on the udders
of cows!

There have also been examples of organisms that are typically found on dogs,
cats and horses!

Lessons learned:

• Personal hygiene for pharmaceutical personnel, both manufacturing


personnel and others who enter manufacturing areas, is important at all
times, not just at work!
• Removing street clothing and regular handwashing in production areas
are necessary

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1.58 Case study - operator error

Notes:

Case Study - Operator Error

1.59 Description of problem

Notes:

This case study involves a semi-automated process for protein capture, which
involved taking the harvest from a cell culture process that involved protein
expression. The harvest was a typical process involving centrifugation to remove
the culture medium, lysis of the cells and capture of the protein that had been
expressed, using a capture chromatography column. Following capture, the

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protein was eluted into an eluate tank and once the protein had been eluted from
the column, the column was cleaned with Sodium Hydroxide solution.

The Sodium Hydroxide was accidentally eluted into the eluate tank with the
protein solution and the entire batch was lost because the Sodium Hydroxide
solution caused hydrolysis and destroyed the protein.

It didn’t just happen once, but it happened twice before the company took
effective action!

1.60 How was this resolved?

Notes:

The automated system should have prevented this error, BUT, the automated
process was overridden by the operator. The root cause was determined to be
the operator, who was counselled and re-trained. However the retraining of the
operator was not sufficient because the same problem occurred again, this time
involving a different operator.

After the second incident the company introduced a fix in the software to prevent
such an operator intervention without a second operator checking. Was this fix
sufficient? The risk still remains because two operators, both with a vested

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interest in taking a short cut, could still, together override the system and there is
a risk, albeit a much smaller risk, that both operators could make the same
mistake.

1.61 Lessons learned

Notes:

The main lesson learned was that while the primary root cause may have been
operator error, there was also a secondary root cause, which might also be
considered as the primary root cause and that is that the automation software
was not secure.

Operators may try to take short cuts to save time, but may not understand the
impact of their shortcuts. The automation was designed to prevent such an error
from occurring, but the flaw in the software design was that it could be overridden
by the operator. Even an override by two operators, is not completely secure.

Operators should not be allowed to override an automated process. Any


override should only be performed by someone with supervisor or administrator
rights and should only be performed under change control or as a planned
deviation (or as a temporary approved change to the process).

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1.62 Final assessment

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