(GLP) - an Overview Overview Overview The GLP have been in existence for non clinical safety studies since 1976. They have been progressed through various transitional phases to become guidelines in some countries and regulatory/statutory instruments in others. Overview The current document is the Organization for Economic Co- operation and Development (OECD) Principles of GLP and is currently accepted as the industry standard.
This was published in January 1997
Overview Guidelines of other countries, i.e USFDA, USEPA (Environmental Protective Agency) are similar rules to OECD principles. If data generated to the OECD principles, will be accepted in US & Japan. Objective of the Guideline Objective of the Guidelines In early 1970’s one company (Industrial Biotest) was found to be generating extremely poor quality data, in a fraudulent manner. This, therefore caused the FDA to put together and implement the GLPs. Objective of the Guidelines Over the next 10 years many countries introduced similar good-practices guidelines. The EU produced a standard document by the OECD in the early 1980s and became industry standard. Objective of the Guidelines Benefit of OECD:
Data generated by one company to
be accepted by several receiving authorities without further inspection. Objective of the Guidelines It must be remembered that GLP is merely commonsense in a formal environment. GLP environment include good documentation, training, maintenance and calibration of all equipment, the archiving and storing of data in a formal and retrievable manner. Who does it affect ? Who does it affect? Any company or institution performing nonclinical safety studies for the submission of data for a new chemical entity. Within a company, every person from Sr.Management to Jr.Technician bound by these GLPs. Why have it ? Why have it? In general terms, For companies conducting nonclinical safety studies, it is, a regulatory requirement, and without this compliance certificate, data will generally not be accepted by the regulatory/receiving authorities Why have it ?
Over the past 5 years, many companies
have gone far beyond the requirements of GLP compliance Why have it? But many laboratories, for example, where the refrigerator has been located far from its permitted limits. Where the temperature recorded, signed and dated as required by GLP, but where neither document the excursions outside the accepted range nor to rectify the problem. Why have it? This is GLP despite the damage that excursions outside the temperature range may have caused to any investigational product stored in the refrigerator. How it Enforced ? How is it Enforced? All countries have a regulatory group, also acts as the receiving authority for the review of data, and reports to the GLP Monitoring Authority. This regulatory group visits on a 2 year basis or in Germany 4 year basis. How is it Enforced? The inspection may be performed by 1 or 2 persons for 1 to 5 days. At the end of day, an exit meeting is held, Non compliance points are noted in writing and discussed and a report is then prepared. What is GLP ? What is GLP? The OECD covers a series of activities and personnel. Responsibilities, Training, Quality Assurance, Standard Operating Procedures(SOPs) Study plan and study reports, What is GLP? Data production and recording, Equipment maintenance and calibration, Computers and validation, Test systems and test substances Archiving areas covered by the GLPs. What is GLP? Responsibilities: The prime players in a GLP scenario would be – a. Management b. The Sponsor c. The Study Director d. The Principle Investigator e. Quality Assurance. What is GLP? Management: would be totally responsible for the conduct of the work. The Sponsor: is the person who is supplying the money and the request for the work. Study Director: is the prime player and is ultimately responsible for the production of the study plan. What is GLP? Principal Investigator: is the next line of responsibility after the Study Director in a multisite study. QA: This will involved in conduct the study, but merely reviews the data, experimental work, ensure the documents compliance to SOPs, the study plan, and GLP. What is GLP? Other activities of QA:
Training and assistance in interpreting
GLPs. What is GLP? SOPs These generally have been likened to a complete documented history of the entire aspect of conducting nonsafety studies. Once produced SOPs must be reviewed on a regulator basis (every 2Years). What is GLP? SOPs: Any changes these procedures must be made in writing. The SOP itself must be filed in the archive, additional copies produced. SOPs must be appear in the adjacent of workplace to all persons. SOPs can be paper-based or electronic. What is GLP? Study Plan and Reports: The study plan is merely an indication of all of the activities that will take place, resources required, time frames and objectives. Both the study plan and report are audited by QA. What is GLP? Data: Raw data is generally considered the first records made, either electronically or paper-based. In regards to the data they should be recorded promptly, legibly and signed and dated. What is GLP? Equipment: GLP requires that equipment be maintained, calibrated, and generally demonstrated as fit for use. Equipment should have a log book that gives a historical record of its use. The calibration and validation should be stated as “fit for use”. What is GLP? Computers: Inspectorate is to ensure that they are fully validated. Validation could be covered by “evidence that the computer will perform the task for which it was purchased and more importantly, continue to perform that task for the foreseeable future. What is GLP? Computers: If in house software programs are produced, are tested and validated and the source code is made available. Important rule is that the “electronic signatures rule”. What is GLP? Archives : Having addressed all the various aspects of the study, one can see that much documentation, tissues, slides and wax blocks could well be accumulating. The requirement is to store this material for a “period of time”. How can compliance be maintained within a Facility? How can compliance be maintained within a Facility? Compliance, having been granted after an inspection, should be monitored on a daily basis. Training and retraining along with an awareness of the requirement to comply with GLP, are immense important. How can compliance be maintained within a Facility? A good point to review internally and on a regular basis: 1. Problems that have been encountered in experimentation. 2. Audit findings. 3. Ways to improve work by looking at new systems and reviewing SOPs to ensure that these are current. 4. Areas where improvements can be made. Pitfalls and Benefits Pitfalls and Benefits An independent body should look at why problems occur and at the sorts of problems that occur and carrying out regular reviews with Sr. management about these problems. Costs will increase because of time pressure and the necessity of involving third party reviews. Pitfalls and Benefits Time must be taken to write and review SOPs. This in itself very costly exercise. One company, having spent more than 6 months to write SOPs and put a value $5500 on that volume. Pitfalls and Benefits All nonclinical safety studies, when conducted according to the principles of GLP and adequately addressing science as well as compliance, can achieve high success rate both in the outcome of the science and in the acceptance of data for a regulatory submission. Thanks