Compliance in the pharmaceutical industry is of utmost importance, not only due to legal requirements but also because this industry cannot afford mistakes. Unlike other sectors where errors might lead to customer dissatisfaction, in pharmaceuticals, errors can range from minor issues to life-threatening consequences. Therefore, ensuring compliance is not just a good practice but an ethical imperative.
The FDA&39;s Good Manufacturing Practices (GMP) for pharmaceutical manufacturing establishes stringent rules for drug companies. These regulations are not confined to the United States; they align with international standards and bear similarities to other quality protocols such as ISO 9001.
But what does "quality" mean in this context? According to the FDA&39;s cGMP, quality means that every pharmaceutical product possesses a defined identity, strength, purity, and other quality attributes, ensuring the required levels of safety and efficacy. In essence, quality signifies a manufacturer&39;s ability to consistently produce the same product according to specifications.
To meet the requirements of periodic review for regulatory compliance in pharmaceutical manufacturing, a robust quality system must be in place, along with thorough documentation of the production process and any issues that arise during a specific period for later review.
Every quality system should include a section detailing how periodic system reviews are conducted. These reviews are a paramount aspect of the system and fall under the responsibility of the company&39;s management, ideally taking place at least once a year.
Within a quality system&39;s approach, some essential requirements for periodic review in pharmaceutical manufacturing compliance include:
1. Evaluating whether the quality policy and objectives remain appropriate or require adjustment.
2. Assessing the outcomes of internal audits.
3. Analyzing customer feedback, including complaints.
4. Reviewing the status of actions taken to prevent potential problems or recurrences.
5. Following up on previous reviews.
6. Considering any changes in the business environment that may impact the quality system.
7. Verifying whether the product characteristics align with customer needs.
During the implementation of the quality system, it is advisable to integrate systematic reviews into management meetings&39; agendas for close monitoring. As the system matures and becomes more stable, the frequency of reviews may decrease, but conducting them at least once a year is essential. For a mature system with fewer issues, quarterly reviews can be considered a suitable rate.
Engaging an external auditor can also be a valuable approach, as an independent professional can provide a fresh perspective and unbiased evaluation of the quality system, unaffected by internal interests.
The outcomes of these reviews should always be documented and translated into planned corrective and preventive actions. Typically, a review results in enhancements to the quality system, improvements in the product or production process, and/or realignment of processes.
Management should refer to specific sections in the cGMP, such as paragraphs 211.100, 211.180(e), 211.192, and 211.198(b)(2), to ensure compliance with the requirements of periodic review for regulatory compliance in pharmaceutical manufacturing.