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The Collegiate Directory of the National Sanitary Surveillance Agency, within its
attributions, granted to it by the art. 11, subparagraph IV, of the ANVISA Regulation, approved
by the Decree No. 3.029, from April 16, 1999, according to the art. 111, subparagraph I, item ‘b’,
paragraph 1 of the Internal Rule approved by the Guideline No. 593, from August 25, 2000,
republished on December 22, 2000, in a meeting called on July 30, 2003,
whereas the need of updating the Good Manufacturing Practices of Drugs, with the
purpose of following the development of new technologies, in the last years, and the
significance of national and international documents on the issue;
adopts the following Collegiate Directory Resolution and I, CEO, determine its publication:
Art. 1 To determine to all manufacturing sites of drugs, the fulfillment of the guidelines
established in the Technical Regulation of Good Manufacturing Practice of Drugs, according to
Annex I of this Resolution.
Art. 2 To institute and approve the Classification and Evaluation Criteria of the items in
the Inspection Guide for Drug Manufacturing Companies, based on potential risk of quality and
safety, inner to the drug manufacturing processes, according to Annex II of this Resolution.
Art. 3 To institute as an inspection rule to the purpose of verifying the fulfillment of the
Good Manufacturing Practice of Drugs, to the sanitary surveillance authorities of the Single
Health System [Sistema Único de Saúde], the Inspection Guide for Drug Manufacturing
Companies, according to Annex III of this Resolution.
Art. 4 The drug manufacturing companies must perform self-inspections, according to the
Technical Regulation of the Good Manufacturing Practice of Drugs and the Inspection Guide in
Pharmaceutical Industry, foreseen in this Resolution, as part of the measures required to their
implementation.
Single paragraph. The reports of self-inspection, related to this article, must be available,
to be handled and/or sent promptly to the fiscal authorities, whenever formally required by them.
Art. 5 The Resolution - RDC No. 134, from July 13, 2001, is revoked.
Art. 6 The Annexes A, B, I and L of Decree - No. 500, from October 9, 1997, are revoked.
Art. 7 The updates of this Resolution, viewing the follow-up of the development of new
technologies, in the pharmaceutical sector, must be approved by the Collegiate Directory of the
National Sanitary Surveillance Agency, and published in the Federal Gazette.
ANNEX I
A. GENERAL CONSIDERATIONS
1. Glossary
1. Quality Assurance
3. Quality Control
5. Validation
6. Complaints
7. Products Withdrawal
10. Personnel
10.1 Generalities
10.3 Training
11. Premises
11.1 Generalities
12. Equipment
13. Materials
13.1 Generalities
13.2 Raw-material
14. Documentation
14.2 Labels
17.5 Sterile products prepared from sterile raw materials, in aseptic conditions
17.6 Personnel
17.7 Facilities
17.8 Equipment
17.9 Sanitization
17.10 Production
17.11 Sterilization
17.17 Filtration of drugs which may not be sterilized in their final containers
18.1 Reach
18.2 Glossary
18.6 Production
18.7 Labeling
19.1 Reach
19.2 Glossary
19.6 Approaches
19.7 Organization
A. GENERAL CONSIDERATIONS
Registered drugs must only be produced by licensed manufacturers, holding the Manufacturing
Authorization, with their activities regularly inspected by the National Sanitary Authorities in
charge. This Regulation of Good Manufacturing Practices (GMP), must be used as reference in
the inspection of the manufacturing site premises, the manufacturing and quality control
processes and as a training material of the drugs sector inspectors, as well as, in the training of
the professionals responsible for the production and Quality Control in industries.
GMP are applicable to all operations involved in the manufacturing of drugs, including those
drugs in development designed to clinical essays.
The Good Manufacturing Practices (GMP) described in this document are passive of continuous
updates, in order to follow the evolution of new technologies. Alternative actions may be
adapted in a way to meet specific needs of certain product, provided that they are validated to
ensure the product quality. GMPs do not cover aspects related to the safety of the personnel
involved in the manufacturing process; these aspects are regulated by a specific legislation.
However, the manufacturer must ensure the safety of its workers.
This document is divided within three parts:
B. First Part: “Quality Management on the Manufacturing of Drugs: philosophy and fundamental
elements” briefs the general concepts of Quality Assurance, as well as the main components
and subsystems of GMP, determines the responsibilities of the superior management team, of
the production management and of the Quality Control, including, but not restricted to, hygiene,
validation, personnel, premises, equipment, materials and documentation.
C. Second Part: “Good Manufacturing and Quality Control Processes”, which acts as a guide of
the actions to be taken separately by the people responsible for the production and the Quality
control in the implementation of the general principles of Quality Assurance.
D. Third Part: It contains the supplementary guidelines to the manufacturing of sterile drugs,
biological products and validation, but it is not a finished section, because it foresees the
inclusion of other matters, such as the ones related to phytotherapeuticals and pharmaceutical
active ingredients (PAIs).
1. Glossary
The definitions presented below apply to the terms used in this Regulation. They may have
different meanings in other contexts.
Adjustment
Operation designed to make a measuring instrument have a performance compatible to its use.
Area
Delimited physical space, where the operations are performed under specific environmental
conditions.
Clean area
Area with environmental control related to the contamination by viable and non-viable particles,
designed, constructed and used in a way to decrease the introduction, generation and detention
of contaminants in its inner part.
Antechamber
Closed space with two or more doors, placed between two or more areas of distinct cleanliness
classes, with the purpose of controlling the air flow between them, when they need to be
entered. The antechamber is designed in a way to be used by people or materials.
Reference sample
Raw materials and finished products samples kept by the manufacturer, duly identified, for a
determined period of time after the finished product expiration date. The amount of sample must
have, at least, the double of the units required to perform all the analyses foreseen in official
compendia.
Representative sample
Amount of sample statistically calculated, representing the sampled universe, taken for
purposes of the analysis to the batch release.
Certification
Verification, upon sanitary inspection, of the whole fulfillment of the Good Manufacturing
Practices in some working production lines, pharmaceutically.
Calibration
Set of operations establishing, under specific conditions, the relation among the values shown
by an instrument or measuring system or values represented by a materialized measure or a
reference material, and the correspondent values of the greatness established by patterns.
Certificate of product registration
Legal document issued by the Sanitary Authority in charge, where the qualitative and
quantitative formula of the product, including details on the package, label and expiration date,
are shown.
Certificate of Good Manufacturing Practices
Legal document issued by the Sanitary Authority in charge, certifying that a certain production
line of the company meets the requirements of the Good Manufacturing Practices.
Concentration
Quantity of active(s) or inactive(s) substance(s) in a determined mass or volume unit of the
product.
Cross-contamination
Contamination of certain raw material, intermediary product, bulk product or finished product by
another raw material, intermediary product, bulk product of finished product, during the
production process.
In-process control
Verifications performed during the production, in order to manage and, if necessary, to adjust
the process to ensure that the product is according to its specifications. The environmental or
equipment control may also be considered an integrating part of the process control.
Component
Any substance or material to be used in the manufacturing of a pharmaceutical product.
Quality deviation
Distancing of the established quality parameters for a product or process.
Edification
Set of architectural premises containing the areas, premises and auxiliary resources.
Packaging
All the operations, including filling and labeling, which the bulk product must go through in order
to become a finished product. Usually, the sterile filling is not considered as a part of the
packaging product, even though the bulk product is kept in the primary container.
Specification
Document describing, in details, the requisites that the products or material used or obtained
must meet during the manufacturing. The specifications act as the basis for the quality
evaluation.
Manufacturing
All the operations including the acquirement of materials, production, quality control, release,
storage, issuing of finished products and the related controls.
Manufacturer
Holder of the Authorization of Establishment to the manufacturing of drugs, issued by the
authority in charge of the Ministry of Health, according to the provided in the current sanitary
legislation.
Master formula/Standard formula
Document or set of documents specifying the raw materials and package materials with their
quantities, together with the description of the procedures and necessary precautions to the
production of a certain amount of finished product. Besides, it provides instructions on the
processing, including the in-process controls.
Installation
Delimited physical space containing machinery, apparatus, equipment and auxiliary systems
used to perform the processes.
Batch
Defined quantity of raw material, packaging material or finished product manufactured in only
one process or process series, which fundamental characteristic is the homogeneity and quality
within the specified limits. In the continuous manufacturing, the batch corresponds to a definite
fraction of the production. Sometimes it is necessary to divide the batch into sub-batches, which
will later be mixed in order to form a final homogeneous batch.
Raw material
Any active or inactive substance, with defined specification, used in the production of drugs.
Packaging material
Any material, used in the packaging process of a certain pharmaceutical product.
Drug
Pharmaceutical product, technically obtained or elaborated, with a prophylactic, healing,
palliative or diagnosis purposes
Batch number
Defined combination of numbers and/or letters identifying a certain batch.
Production order
Reference document to the production of a drug batch, comprehending the information of the
master formula/standard formula.
Authorized Person
Licensed professional in the area of drugs, indicated by the company, responsible for the
release of the batches of finished products to their distribution and selling.
Strength
Therapeutic activity of the pharmaceutical product according to the shown by lab essays, or by
clinical data properly developed and controlled.
Expiration Date
Limited date to the use of a pharmaceutical product defined by the manufacturer, based on its
respective tests of stability, the storage conditions kept and transportations established by it.
Standard Operation Procedure (SOP)
Written and authorized procedures providing detailed instructions to the performance of specific
operations in the manufacturing of a pharmaceutical product and other general nature activities.
Process
Set of procedures to the performance of a determined operation, following the techniques, rules,
and specifications.
Production
All the operations involved in the preparation of a determined pharmaceutical product, since
receiving the materials from the warehouse, passing by processing and packaging, until the
obtainment of the finished product.
Bulk product
Any product that went through all the production steps, not including the packaging process.
The injectables in their primary package are considered a bulk product.
Returned product
Finished product, marketed and issued, returned to the manufacturer.
Intermediary product
Product partially processed, which must go through the subsequent production steps.
Finished product
A product that went through all the production steps, including labeling and final packaging.
Medical Control Program of Occupational Health:
With the purpose of promoting and preserving the health of all the workers. It is an inner part of
the broader group of initiatives of the company in the workers health field. It shall consider the
incidental questions about the individual and the group of workers, giving place to the clinical-
epidemiological instrumental in the approach of the relation between your health and your work.
It shall have a prevention, tracking and early diagnosis character of the damages to health
related to work, including the ones of sub-clinical nature, besides of noticing the existence of
cases of professional disease or irreversible damages to the workers’ health.
Qualification
Operations documented according to a pre-determined tests plan and defined acceptance
criteria, ensuring that components, equipment and premises are appropriate to the intended
use.
Quarantine
Temporary detention of raw material, packaging material, intermediary products, bulk or finished
products, while awaiting the release decision, rejection or reprocessing.
Reanalysis
Analysis performed in a raw material, previously analyzed and approved, in order to confirm the
maintenance of the specifications established by the manufacturer, within its expiration date.
Reconciliation
Procedure with the purpose of comparing the actual production quantity and the established
theoretical quantity in the different production steps of a product batch.
Recovery
Total or partial incorporation of previous batches, of proven quality, to other batch, in a defined
production step.
Batch record
Set of documents related to the manufacturing of a determined batch of finished product. These
documents describe the production procedures and record all the operations related to the
batch quality.
Reprocessing
Rework of all or part of a batch of the product out of one or more established quality
parameters, from a defined production step, so its quality may become acceptable through one
or more additional operations. The reprocessing must be previously authorized and performed
according to approved procedures.
System
Regulated standard of activities and interactive techniques gathered to form an organized set.
Great Volume Parenteral Solutions (GVPS)
Aqueous, sterile, apyrogenic solutions, filled into a single container of 100 ml or more, with final
sterilization. In this definition are included the solutions to intravenous administration, solutions
for irrigation and solutions for peritoneal dialyses.
Active substance
Any substance presenting a pharmacological activity or other direct effect on the diagnosis,
healing, relieve, treatment or prevention of diseases, or which affects the human body
functioning.
Validation
Documented act attesting that any procedure, process, equipment, material, operation or
system really leads to the expected results.
B. FIRST PART: Quality Management on the Manufacturing of Drugs: philosophy and essential
elements.
The quality management is the aspect of the management function which determines and
implements the “Quality Policy”, i.e., the global intentions and directions related to quality,
formally expressed and authorized by the superior management team of the company.
The basic elements of the quality management are:
- appropriate infrastructure or “quality system”, comprehending organizational structure,
procedures, processes and resources;
- systematic and accurate actions in order to ensure that a certain product (or service) meets
the requirements as for its quality. The set of these actions is called “Quality Assurance”. Within
an organization, the Quality Assurance acts as a management tool. In situations provided in
agreements, the Quality Assurance acts, also, to provide truth in the supplier.
In the manufacturing and supply of drugs, the term “Quality Assurance” comprehends elements
such as the organization structure, processes and procedures. The concepts of Quality
Assurance, GMP and Quality Control are inter-related aspects of quality management. They are
written in this Regulation in order to emphasize their relations and essential significance to the
manufacturing of drugs.
1. Quality Assurance
1.1 “Quality Assurance” is the whole set of actions taken with the purpose of ensuring that the
drugs are within the quality standards requires, so they can be used for due purpose. Therefore,
Quality Assurance comprehends GMPs and other factors, including the design and
development of a product, which are not covered by the purposes of this Regulation.
1.2 An appropriate Quality Assurance system, applied to the manufacturing of drugs, must
ensure that:
(a) the drugs as designed and developed taking into consideration the need of fulfilling the GMP
and other requests such as Good Laboratory Practices (GLP) and Good Clinical Practices
(GCP);
(b) the operations of production and control are clearly specified, in written, and the GMP
requirements are met;
(c) the management responsibilities are clearly specified in the description of titles and
functions;
(d) actions are taken as for the manufacturing, supply and correct use of raw materials and
package materials;
(e) all the controls are performed in the raw materials, intermediary products, bulk products, as
well as other in-process controls, calibrations and validations;
(f) the finished product is correctly processed and checked, according to defined procedures;
(g) the drugs are not issued before authorized persons have certified that each production batch
was produced and controlled according to the requests of the record and other applicable
regulations related to the production, control and release of pharmaceutical products;
(h) instructions are provided and the necessary actions are taken in order to ensure that the
drugs are stored by the manufacturer, distributed, and subsequently, handled, so their quality is
maintained during all period before expiration date;
(i) there is a self-inspection and/or internal audit procedures of the quality, evaluating, regularly,
the effectiveness and the application of the Quality Assurance system.
1.3 The manufacturer is responsible for the quality of the drugs it manufactures, ensuring that
they are appropriate to the purpose they are intended for, meet the requirements established in
their records and do not place the patients’ at risk for presenting inappropriate safety, quality or
efficacy. Meeting this purpose is the responsibility of the superior management team of the
company and it required the participation and commitment of employees in the many
departments and in all organization, supplying companies and distributors levels. In order the
achieve the quality purpose trustfully, there must be a Quality Assurance system totally
structured and correctly implemented, incorporating the GMPs. This system must be totally
documented and must have its effectiveness monitored. All the parts of the Quality Assurance
system must be constituted by competent and licensed personnel, besides having enough and
appropriate space, equipment and premises.
2. Good Manufacturing Practices for Drugs (GMP)
2.1 Good Manufacturing Practice is the part of the Quality Assurance ensuring that the products
are consistently produced and controlled, with quality standards appropriate to the intended
use, requested by the registration. The fulfillment of GMP is firstly oriented to decrease the
inherent risks to any pharmaceutical production, which cannot be detected through essays in
the finished products. The risks are essentially constituted by: cross-contamination, particles
contamination and exchange or mixing of products.
2.2 The GMPs determine that:
(a) all the manufacturing processes must be clearly defined and systematically revised in
relation to the experience obtained. Besides, they must be able to manufacture drugs, within the
quality standards required, meeting the respective specifications;
(b) the critical steps of the manufacturing processes and any significant change must be
systematically validated;
(c) the production areas must be provided with all the infrastructure required, including:
qualified and duly trained personnel;
appropriate space and premises;
appropriate equipment and services;
appropriate materials, containers and labels;
approved procedures and instructions;
appropriate storage and transportation;
premises, equipment and qualified personnel, to the in-process control;
(d) the instructions and procedures must be written in a clearly, unambiguous language and
must be specifically applicable to the premises used;
(e) operators must be trained to perform the procedures correctly;
(f) records must be done (manually and/or through recording instruments) during the production,
in order to show that all the steps contained in the procedures and instructions were followed
and that the quantity and quality of the product obtained are according to the expected. Any
significant deviation must be recorded and investigated;
(g) the records related to the manufacturing and distribution, making the complete tracking of a
batch possible, must be kept organized and easy to access;
(h) the appropriate storage and distribution of products must minimize any risk to its quality;
(i) a system able to collect any batch, after its sale or supply, must be implemented;
(j) the complaints on marketed products must be examined, registered and the quality deviation
causes must be investigated and documented. Measures must be taken in relation to the
products presenting quality deviations and actions must be adopted in order to prevent
reoccurrences.
3. Quality Control
3.1 Quality control is a part of GMP related to the sampling, specifications, essays, organization
procedures, documentation and release procedures ensuring that the necessary and significant
essays are performed and that materials are not released to use, nor to sales or supply, until
their quality is considered satisfactory. The quality control must not be limited to the laboratory
operations, it must also be involved in all decisions related to the product quality.
3.2 All the holders of Authorization of Establishment to manufacture drugs must have a Quality
Control. It is essential that the quality control is independent of the production. The quality
control must be independent from the other departments and it must be under the direction of a
qualified and experienced person, with one or many control laboratories available. Appropriate
resources must be available in order to guarantee that all of the quality control activities are
effective and trustfully performed.
The minimum requirements to the quality control are the following:
(a) appropriate premises and personnel, trained personnel and operation procedures approved
must be available so the sampling, inspection and essays of raw materials, packaging materials,
bulk products and finished products may be performed, whenever necessary, to manage the
environmental conditions of the areas;
(b) the sampling of raw materials, packaging materials, intermediary products, bulk products
and finished products, must be performed through approved methods and by qualified
personnel;
(c) the analysis methods must be validated;
(d) the records must be done (manually and/or through recording instruments), showing that all
the sampling procedures, inspections and essays required, are really performed and that any
deviation is totally investigated and documented;
(e) the finished products must have inputs, meeting the quantitative and qualitative composition
described in the product registration; the substances must present the required purity, must be
packaged into appropriate containers, correctly labeled.
(f) the results obtained in the inspections and the materials, intermediary products, bulk
products or finished products control essays for meeting the specifications, must be recorded.
The products batches evaluation must include the revision and evaluations of the production
documentation, as well as, the evaluation of the deviations to specific procedures;
(g) no product batch may be released to expedition before being approved by the authorized
person, who must indicate that it is according to its specifications;
(h) sufficient samples of the raw materials and the finished products must be taken, in order to
perform later product examinations, if necessary; the samples of finished product taken must be
kept in their final packages, in the established storage conditions, unless they are exceptionally
large;
3.3 The quality control has, yet, other attributions, such as establishing, validating and
implementing its procedures to evaluate, keep and store the reference standards of the active
substances used; ensuring the proper labeling of the material and product containers; ensuring
that the active substances and the products stability is monitored; taking part in the investigation
of the complaints related to the product quality and taking part in the environmental
management. All these operations must be performed according to the approved, and
whenever required, registered Standard Operation Procedures (SOP).
3.4 The evaluation of the finished products must comprehend all the significant factors,
including the production conditions, the results of the in-process control, the manufacturing
documents, the meeting of the finished product specifications and the examination of the final
package.
3.5 The company Quality Control personnel must have access to the production areas in order
to perform the sampling and investigation activities, as appropriate.
4. Sanitization and Hygiene
4.1 The production of drugs requires a high sanitization and hygiene levels, that must be kept in
all manufacturing procedures. The sanitization and hygiene activities must comprehend
personnel, premises, equipment and apparatus, production materials and containers, cleaning
and disinfectant products and any other aspect which may constitute a contamination source to
the product. The potential contamination sources must be eliminated through a broad
sanitization and hygiene program.
5. Validation
5.1 The validation studies constitute an essential part of the GMP and, therefore, they must be
conducted according to predefined protocols. A written report must be kept with the summary of
the results obtained and the conclusions. The processes and procedures must be established,
according to the validation study results and they must be periodically revalidated, so to ensure
that they are able of reaching the planned results. Special attention must be given to the
validation of processes, control essays and cleaning procedures.
5.2 The processes considered critical must be validated, concurrently, prospectively and/or
retrospectively.
5.3 When there is a change in the master formula/standard formula or a new preparation
method is introduced to the usual manufacturing processes, the appropriateness of the new
method to the established routine processes must be shown by validation. The process defined
upon the use of the specified materials and equipment, must show to be able of originating
uniform products, within the required quality standards.
5.4 The manufacturing processes suffering any significant change, including any equipment or
materials change which may affect the quality and/or reproducibility of the process, must also be
validated.
6. Complaints
6.1 All the complaints and other information related to products with possible quality deviations,
must be carefully investigated and registered according to the written procedures.
6.2 A person responsible for the receiving of complaints and for the actions to be taken must be
indicated. This person must have enough support personnel to help him/her in this function. If
the person indicated is not the Technician Responsible for the product, he/she must be
informed.
6.3 In case of complaints of possible quality deviation of a product, the written procedures
describing the actions to be taken, including the need to perform a likely collection, must be
adopted.
6.4 Any complaint related to a quality deviation in a certain product must be registered, together
with all the details in the batch records and, then, it must be completely investigated. The
person responsible for the Quality Control must be involved in the study of the related deviation.
6.5 If a quality deviation is detected in some product batch, or if there is a likely suspicion of
deviation of a certain batch, the possibility that other batches present the same problem it must
be taken into account, therefore, they must also be verified. Other batches containing the
reprocessed product of the batch presenting deviations, must be specially investigated.
6.6 Whenever required, the appropriate actions of follow-up must be adopted after the
investigation and evaluation of the complaint, including the possibility of collecting the product.
6.7 All the decisions and measures taken as a result of certain complaint must be registered
and mentioned in the correspondent batch records.
6.8 The complaint records must be regularly revised, with the purpose of detecting any mark of
specific or recurrent problems, which require more attention and may justify the collection of the
marketed products.
6.9 The sanitary authorities in charge must be informed by the manufacturer when any
significant quality deviation in the manufacturing process, product deterioration is detected, and
when a serious problem with the quality of some product is under investigation.
7. Products Collection
7.1 There must be a system for the immediate and efficient withdrawal of products presenting
quality deviations or under suspicion from the market.
7.2 A person responsible for the measures to be adopted and the coordination of the product
collection from the market must be indicated. This person must have enough support personnel
in order to help him/her in all of the aspects of the collection and with the necessary urgency
level. Usually, this person must not belong to the selling and marketing authority, and if he/she
is not the Technician Responsible for the product, the latter must be informed of any action
taken.
7.3 There must be written procedures, regularly verified and updated, to proceed with any
collection activity. The collection operations of the product in the market must be immediate,
starting, most preferably, by hospitals and drugstores. The procedures viewing the destination
of the collected products, which were deviated from the transportation and/or distribution chains
must be foreseen.
7.4 All of the sanitary authorities in charge in the countries the product was sent to must be
immediately informed about any intent collection of the product presenting a quality deviation or
under suspicion.
7.5 The records about the batch distribution presenting a quality deviation or under suspicion
must be immediately available to the person responsible for the collection. The records must
have enough information on the distributors and on the buyers who may have been directly
supplied with the product, including in case of exported products information on the buyers who
received samples to perform clinical trials and medical samples, so the product is efficiently
withdrawn from the market.
7.6 The collection process progress must be recorded, including the reconciliation between the
distributed quantities and the collected quantities of the product, as well as a final report.
7.7 The efficiency of the activities related to the recollection must be periodically evaluated.
7.8 An instruction indicating the storage conditions of the products withdrawn from the market,
which must be kept in safety, in separated areas, while awaiting the decision about their
destination, must be included.
8. Manufacturing and/or Analysis Agreement
8.1 The manufacturing and/or analysis agreement must be mutually agreed and controlled
between the parties, to avoid mistakes which may result in a process, product or analysis of
unsatisfactory quality. A written agreement must be signed between the contracting and the
contracted parties, clearly establishing the attributions of each party. The agreement must
establish the procedure upon which the authorized person must exercise its responsibilities, as
for the release of each product batch for sale or as for the issuing of a certificate of analysis.
8.2 All the conditions established in the manufacturing and/or analysis agreement must include
any change proposed in the technical procedures which must be in accordance with the
registration of the respective product.
8.3 The written agreement signed must establish the manufacturing and/or analysis procedures
of the product with all the technical activities related to both.
8.4 The agreement must establish that the contacting party may perform an audit in the
contracted party premises.
8.5 In case of an analysis agreements, the final approval to the release of the finished product
for marketing, must be given by the contracting party authorized Person.
8.6 The contracting party is responsible for the qualification evaluation of the contracted party to
perform the contracted services. Besides, it must be assured, by the signed agreement, that the
GMP principles described in this Regulation are followed.
8.7 The contracting party must provide the contracted party with all the information required to
perform the contracted operations according to the product registration, as well as any other
legal requirements. The contracting party must ensure that the contracted party is informed of
any problem related to the product, service or essays, placing their premises, equipment,
personnel, other materials or products at risk.
8.8 The contracting party must ensure that all the processed products and materials delivered
by the contracted party meet their specifications or that the product has been released by the
Authorized Person.
8.9 The contracted party must have appropriate premises, equipment and knowledge, besides
experience and qualified personnel, in order to satisfactorily perform the service requested by
the contracting party. The manufacturing contract may only be performed by manufacturers
holding a Certificate of Establishment and Sanitary License.
8.10 The contracted party may not repass the services foreseen in the contract to third parties
without the previous evaluation and approval by the contracting party of this agreement change.
The agreements signed between the contracted party and third parties, must foresee the
availability of analytical information and information on the manufacturing, just as the
agreements signed between the contracting and the contracted parties.
8.11 The contracted party must abstain from performing any activity which may adversely affect
the quality of the manufactured and/or analyzed product to the contracting party.
8.12 The agreement signed between the contracting and the contracted parties must specify the
responsibilities of the related parties as for the manufacturing and the control of the product.
Technical aspects of the agreement must be written by qualified persons, with the required
knowledge in pharmaceutical technology, quality control analyses and GMP. All the actions
related to the manufacturing and analysis must be according to the product registration and
must be agreed by both parties.
8.13 The agreement must specify the mean by which the Authorized Person ensures that each
batch is manufactured according to the Product Registration.
8.14 The agreement must clearly describe the responsibilities for the acquirement, control essay and
material release, by the production and performance of the quality controls, including the in-process
controls, as well as the responsibilities by the sampling and performance of the analyses.
8.15 The agreement must establish that the manufacturing records, the analytical records and
the reference samples must be kept by the contracting party or must be available to it.
8.16 The agreement must establish that the distribution records must be kept by the contracting
party.
8.17 The agreement must predict the actions to be adopted when there is disapproval of raw
materials, intermediary products, bulk products and finished products.
9. Self-Inspection and Quality Audit
The purpose of the self-inspection is to evaluate the fulfillment of GMP by the manufacturer in
all of the aspects of production and the quality control. The self-inspection program must be
designed in a way to detect any deficiency in the GMP implementation and to recommend the
necessary corrective actions. The self-inspection must be routinely performed, in cases of
product withdrawal or repeated disapprovals. The team responsible for the self-inspection must
be constituted by professionals who may objectively evaluate the fulfillment of GMP. All the
recommendations on the corrective actions must be implemented. The procedures to the
performance of the self-inspection must be documented and also have an effective follow-up
program.
Written procedures must be elaborated on the self-inspection, in order to have a minimum and
uniform standardization of the requirements. These procedures must comprehend, at least, the
following aspects:
(a) personnel;
(b) premises;
(c) maintenance of buildings and equipment;
(d) storage of raw material, packaging material and finished product;
(e) equipment;
(f) manufacturing and in-process control;
(g) quality control;
(h) documentation;
(i) sanitization and revalidation;
(j) validation and revalidation programs;
(k) calibration of instruments and measuring systems;
(l) collection procedures of the product from market;
(m) management of complaints;
(n) labels control;
(o) wastes disposal;
(p) results of previous self-inspections and any corrective actions adopted.
9.1 Self-inspection team
9.1.1 The Quality Assurance management must designate a team to perform the self-
inspection, formed by qualified professionals and experts in their own acting areas and familiar
to the GMPs. The team members may be company employees or outer experts.
9.2 Frequency of the self-inspection
9.2.1 The frequency of the self-inspections must be, at least, annual.
9.3 Self-inspection report
9.3.1 A report must be done after the self-inspection is finished, and it must contain:
(a) the self-inspection results;
(b) evaluations and conclusions;
(c) the corrective actions recommended.
9.4 Follow-up actions
9.4.1 The Company Management and the Quality Assurance must evaluate the self-inspection,
as for the corrective actions recommended, if required.
9.4.2 The verification of the fulfillment of the corrective actions, recommended in the Self-
Inspection report must present a specific report.
9.5 Quality audit
9.5.1 The self-inspection complementation with quality audits may be necessary. The quality
audit consists in the examination and evaluation of part or totality of a certain quality system,
with the specific purpose of enhancing it. Generally, it is performed by outer, independent
experts or by a team designated by the management for this purpose. Besides, the audits may
be extended to suppliers and contracted parties.
9.6 Suppliers audit
9.6.1 The Quality Assurance must be responsible, together with the departments involved in the
manufacturing, by the qualification of the suppliers of raw materials and packaging materials, in
order to meet the established specifications.
9.6.2 Before the suppliers are approved and included in the suppliers list of the company, they
must be evaluated, whenever applicable, by audits, viewing the verification of the fulfillment of
GMPs.
10. Personnel
10.1 Generalities
10.1.1 The establishment and maintenance of a Quality Assurance system and the
manufacturing of drugs, depend on the personnel performing them. For this reason, there must
be qualified personnel enough to perform all the activities the manufacturer is responsible for.
All the individual responsibilities must be established on written procedures and they must be
clearly understood by all the people involved.
10.1.2 The manufacturer must have a sufficient number of qualified persons. The
responsibilities attributed to each employee must not be too extensive, putting the product
quality at risk.
10.1.3 The company must have an organization chart. All the employees with responsibility
status must have their specific attributions written and enough authority to perform them. Their
attributions may be delegated to designees, with a satisfactory qualification level. There may not
be a failure or overlapping in the personnel responsibilities as for the application of GMPs.
10.1.4 All personnel must know the GMP principles and receive initial and continuous training,
including hygiene instructions as needed. All personnel must be motivated to support the
company in maintaining the quality standards.
10.1.5 Actions must be taken in order to avoid the entrance of non-authorized persons in the
manufacturing, storage and Quality Control areas. People not working in these areas must not
use them as a shortcut.
10.2 Main Personnel
10.2.1 All professionals acting in the drugs manufacturing, occupying the main positions in the
company and having the power of decision. The main personnel includes the person
responsible for the manufacturing, for the Quality Assurance, for the quality control, for sales
and distribution and the technical responsible. The person responsible for the production and
Quality Control must be independent from each other.
10.2.2 The main positions must be occupied by people who work full time in the company. In
large companies, there may be the need to delegate some functions, however, responsibilities
may not be delegated.
10.2.3 The persons responsible by the departments of manufacturing, Quality Control and
Assurance of drugs, must have the graduation qualifications foreseen by the current legislation
and practical experience.
10.2.4 The persons responsible for the production, Quality Control and Assurance, under
certain circumstances, must work together, such as:
(a) authorization of procedures and documents, including their updating;
(b) management and control of the manufactory environment;
(c) hygiene;
(d) validation of process and calibration of analytical instruments;
(e) training, including the application of the quality assurance principles;
(f) approval and monitoring of material suppliers;
(g) approval and monitoring of the contracted manufacturers;
(h) specifications and monitoring of the storage conditions of materials and products;
(i) documents/ records archive;
(j) monitoring of the GMP achievement;
(k) inspection, investigation and sampling, in order to monitor factors that may affect the product
quality.
10.2.5 The person responsible for the production, usually, holds the following responsibilities:
(a) to ensure that the products are produced and stored according to the appropriate
procedures, with the quality required;
(b) to approve the instructions related to the manufacturing operations, including the in-process
controls, and ensuring their strict implementation;
(c) to ensure that the manufacturing records are evaluated and signed by a person designated,
before it is made available to the quality control;
(d) to verify the maintenance of the premises and equipment;
(e) to ensure that the processes validations, the calibrations and control of equipment are
performed and recorded and that the reports are available;
(f) to ensure that the appropriate initial and continuous training is performed with the personnel
in the production area, and that it is appropriate to the needs.
10.2.6 The person responsible for the Quality Control has the following responsibilities:
(a) to approve or reject the raw materials, the packaging materials and the intermediary
products, bulk or finished;
(b) to evaluate the batches records;
(c) to ensure that all the essays required are performed;
(d) to approve the sampling instructions, the specifications, the essay methods and the
procedures of quality control;
(e) to approve and manage the analyses performed, foreseen in an agreement;
(f) to verify the maintenance of the premises and equipment;
(g) to ensure that the necessary validations are done, including the validation of the analytical
procedures and the calibration of the control equipment;
(h) to ensure that initial and continuous trainings of the personnel of the Quality Control area are
performed, according to the sector needs.
10.3 Training
10.3.1 The manufacturer, upon a written and defined program, must train the people involved in
the production areas, quality control laboratories, as well as all people whose activities may
interfere with the product quality.
10.3.2 Besides the theoretical and practical basic training of GMP, recently hired people must
take part into the integration program and receive the appropriated training as for their
attributions and they must be continuously trained and evaluated. The training programs must
be made available for all personnel, as well as approved by the persons responsible for the
production, quality control and Quality Assurance, keeping records.
10.3.3 Personnel working in clean areas, in areas with contamination risks, where highly active,
toxic, infectious or sensitizing materials are handled, must receive a specific training.
10.3.4 The concept of Quality Assurance and all the measures which may enhance its
understanding and its implementation must be broadly discussed during the training.
10.4 Health, Hygiene, Garments and Conduct
10.4.1 All the personnel must be subjected to a health evaluation before their admission and
then, from time to time, required to the activities performed, according to the established
procedures.
10.4.2 All personnel must be trained in the personal hygiene practices. All the people involved
in the manufacturing processes must meet the hygiene rules; especially, they must be
instructed to wash their hands before getting into the production areas. In order to have this rule
obeyed, instructive signs must be affixed and they must be observed.
10.4.3 The people with suspicion or confirmation of an illness or exposed wound which may
adversely affect the products quality, may not handle raw materials, packaging materials,
intermediary products and bulk products or finished products until his/her health status does not
represent a risk to the product.
10.4.4 All the employees must be instructed and motivated to report immediately to their
supervisor any condition, related to the production, equipment or personnel, which they consider
that may adversely interfere in the products.
10.4.5 Direct contact between the operator’s hands and the raw materials, primary packaging
materials, intermediary products and bulk products must be avoided.
10.4.6 In order to ensure the product protection against contaminations, the employees must
wear clean garments, appropriate to each production area. If reusable, the uniforms must be
kept in closed environments, until they are washed, and when applicable, disinfected or
sterilized.
10.4.7 The uniforms must be provided by the manufacturer according to written procedures. The
washing of the uniforms is a company responsibility.
10.4.8 In order to ensure the employees safety, the manufacturer must have a Collective
Protection Equipment (CPE) and Individual Protection Equipment (IPE) according to the
activities developed.
10.4.9 It is prohibited to smoke, eat, drink, chew or keep plants, food, drinks, tobacco and
personal drugs in the production areas, quality control laboratory and storage areas or any other
areas where these actions may adversely affect the product quality.
10.4.10 The personal hygiene procedures, including wearing appropriate clothes, must be used
by all the people entering the production areas.
10.4.11 Visitors and non-trained people, must be prohibited of entering the production areas. If
this is unavoidable, these persons must be previously oriented on personal hygiene and
wearing appropriate garments and they must be accompanied by a designee.
11. Premises
11.1 Generalities
11.1.1 The premises must be located, designed, built, adapted and kept properly for the
operations being performed. Its design must minimize the risk of mistakes and make the
cleaning and maintenance possible, in a way to avoid cross-contamination, accumulation of
dust and dirt or any adverse effect that may affect the products quality.
11.1.2 The premises must have environments presenting a minimum risk of contamination of
materials or products handled there when taken into consideration together with the measures
designed to protect the manufacturing operations.
11.1.3 The premises used in the manufacturing of drugs must be designed and built in a way to
make the appropriate cleaning possible.
11.1.4 The premises must be kept in good conservation, hygiene and cleaning status. It must be
ensured that the maintenance and repairing operations do not present any risk to the products
qualities.
11.1.5 The electric power, illumination, air conditioning (temperature and humidity) and
ventilation supply must be appropriate, in order not to directly or indirectly affect the drugs
during the manufacturing and storage processes or the appropriate functioning of equipment.
11.1.6 The premises must be designed and equipped in order to allow the maximum protection
against the entrance of insects and other animals.
11.2 Auxiliary areas
11.2.1 The resting rooms and cafeteria must be apart from the other areas.
11.2.2 The locker rooms, lavatories, and restrooms must be of easy access and appropriate to
the number of users. The restrooms must not have direct communication with the production
and storage areas.
11.2.3 The maintenance areas must be at separated sites from the production areas. If the tools
and repair parts are kept in the production area, they must be in rooms or lockers reserved to
this purpose.
11.2.4 The biotherium must be isolated from the other areas, have a separate entryand an
exclusive ventilation system.
11.3 Storage areas
11.3.1 The storage areas must have capacity enough to make the organized storage of a
number of materials categories and products possible: raw materials; packaging materials;
intermediary products, bulk products and finished products, in their quarantine, approved,
reproved, returned or collected status.
11.3.2 The storage areas must be designed in a way to ensure the ideal storage conditions.
They must be kept clean, dry and with temperatures compatible to the materials stored. When
special storage, temperature and humidity conditions are required, they must be provided,
verified, monitored and registered.
11.3.3 In the receiving and issuing areas the materials must be protected against the
temperature ranges. The receiving areas must be designed and equipped to allow that the
materials containers are cleaned before their storage.
11.3.4 The quarantined products must be in a restricted and separated storage area. This area
must be clearly marked and their access allowed only to authorized persons. Any other system
substituting the physical quarantine must offer the same safety, ensuring its release to
marketing.
11.3.5 There must be a separated area to the collection of raw materials samples. If the
sampling is performed in the storage area, it must be performed in a specific environment for
this purpose, in order to avoid the possibility of microbiological contamination and/or cross-
contamination.
11.3.6 The storage of materials or products returned, reproved or collected must be done in a
separated and identified area.
11.3.7 The highly active materials, substances presenting risk of dependency, fire or explosion
and other dangerous substances must be stored in secure and protected areas, duly separated
and identified, according to the specific current legislation.
11.3.8 The storage of printed materials must be done safely, with restricted access, avoiding
mixings and deviations, and it must be handled by a designee, following the defined and written
procedures.
TABLE 1
Air classification system for the production of sterile products a
At rest In operation
Maximum number allowed of Maximum number allowed of
Grade
particles/m3 particles/m3
0.5-5.0 µm Above 5.0 µm 0.5-5.0 µm Above 5.0 µm
A* 3 500 0 3 500 0
B 3 500 0 350 000 2 000
C 350 000 2 000 3 500 000 20 000
D 3 500 000 20 000 Undefined Undefined
a
Source: WHO Technical Report Series, No. 902, 2002
17.1.4 To obtain air with the required characteristics, specific methods must be used and it must
be observed that:
(a) the air laminar flow system must have a homogeneous speed of about 0.30 m/s, in case of
vertical flow, and 0.45 m/s in case of horizontal flow. The speed accuracy of the air flow
depends on the type of equipment.
(b) to achieve grades B, C and D, the total number of air exchange of the area, usually must be
superior to 20 exchanges per hour, in a room with the appropriate standard of air flow with filters
HEPA (High Efficiency Particulate Air);
(c) the size of the air samples must be large and sufficient, in order to make the low
contamination determination trustful.
(d) The different air particle classification systems for clean areas are presented on Table 2.
(e) There may be difficulty to demonstrate the accordance to the air classification in the filling
point, during this operation, due to the formation of particles/droplets arising from the product
itself.
17.1.5 Each production operation required a determined purity level of the air to minimize the
risks of contamination by particles or microorganisms in the products or materials handled. The
levels of particles or microorganisms presented on Table 1 must be kept next to the product,
everytime it is exposed to the environment. These conditions must also be respected in all of
the surrounding areas.
17.1.6 If, for any reason, the air conditions in the working area are not kept in accordance with
the pre-established conditions, a cleaning/sanitization procedure must be performed to achieve
the appropriate conditions.
17.1.7 The use of the absolute barrier technology (closed systems) and automate systems to
minimize the human intervention in the production areas may bring advantages to the
maintenance of the manufactured products sterility. When these techniques are used, the
recommendations related to the air quality and its management must be applied and the
appropriate interpretation of the words “working place” and “environment” must be done.
17.2 Sterile products production
17.2.1 The production operations are divided, herein, into three categories:
First - when the product is filled and closed in its primary container and then sterilized;
Second - when the product is sterilized by filtration and filled into previously sterilized
containers;
Third - when the product cannot be sterilized by filtration neither by final sterilization,
consequently it has to be produced from sterile raw materials and filled aseptically into
previously sterilized containers.
17.2.2 The grades of each production area are specified on items 17.3, 17.4, and 17.5 and must
be selected by the manufacturer based on the type of product and the correspondent
validations.
17.3 Products with final sterilization
17.3.1 In general, the solutions must be prepared in areas presenting grade C, to a low initial
counting of microorganisms and particles, creating the appropriate conditions to the immediate
filtration and sterilization. The solutions preparation may be performed in grade D environments,
if additional measures to minimize contamination, such as the use of closed containers, are
taken.
17.3.2 In case of parenteral solutions, the filling must be done under a laminar air flow (grade
A), installed in a grade C area. The preparation of other sterile products, i.e., ointments, creams,
suspensions and emulsions, as well as the filling of the respective containers usually must be
conducted in a grade C environment, before final sterilization.
17.4 Products sterilized by filtration
17.4.1 The handling of raw materials and the preparation of solutions must be performed in
grade C areas. If additional measures are taken to minimize contamination, such as the use of
closed containers before filtration, these activities may be performed in a grade D environment.
After filtration, the product must be handled in a grade A or B area, surrounded by grade B or C,
respectively.
17.5 Sterile products prepared from sterile raw materials, in aseptic conditions
17.5.1 The handling of raw materials and all the additional processing must be done in grade A
or B areas, surrounded by grade B or C areas, respectively.
17.6 Personnel
17.6.1 During the development of the aseptic processes, it is essential that the minimum
personnel required is in the clean areas. If possible, the inspections and controls must be
performed outside these areas.
17.6.2 All personnel (including cleaning and maintenance staff) developing activities in these
areas must receive regular training on the issues significant to the sterile products production,
including the mention of personal hygiene and basic concepts of microbiology issues. If
required, the entrance of people not trained in these areas (i.e., people hired for construction or
maintenance), special cares must be taken in relation to their supervision.
17.6.3 The employees taking part in activities related to the production of products in animal
tissue substrate or microorganisms cultures different from the ones used in the manufacturing
process in course, must not enter the production areas of sterile products, unless previously
established decontamination procedures are applied.
17.6.4 The adoption of high standards on personal hygiene and cleaning is essential. People
involved in the manufacturing of drugs must be instructed to communicate their superior of any
change in their health condition, which might contribute to the dissemination of contaminants. It
is convenient to perform periodic health examinations. The actions to be taken in relation to the
people which might be introducing improper microbiological risks must be taken by people in
charge designated to it.
17.6.5 The personal clothes must not be brought into the clean areas. People entering the
lockers of these areas must already be wearing the standard uniforms of the manufacturing site.
The clothes changing and hygiene processes must follow written procedures.
17.6.6 The garments and their quality must be adapted to the process and working area.
Besides, it must be wore in order to protect the product from contaminations.
17.6.7 Wristwatches and jewelry must not be worn in the clean areas, as well as cosmetic
products.
17.6.8 The garments worn must be appropriate to the classification of the clean area where the
personnel is working, and the following must be observed:
Grade D: Hair and beard must be covered. Protecting garments and shoes, or shoe protectors,
proper for the are must be worn. Appropriate measures must be taken in order to avoid any
contamination from external areas.
Grade C: Hair and beard must be covered. Appropriate garments, tightened around the pulse
and with turtle neck must be worn. The garment may not have loose fibers or particles. Besides,
shoes or shoe protectors proper for the area must be worn.
Grade B: A hood covering all the hair and beard, with its inferior border inside the garments
must be worn. A mask must be used on the face, in order to avoid sweat drops to spread.
Sterilized gloves, with no talc, disinfected or sterilized boots must also be worn. The pants hem
must be placed inside the boots, as well as the sleeves must be placed inside the gloves. The
protecting garment must not loose any fiber or particle and it must detain the particles released
by the body of whom wears it.
17.6.9 All employees working in grades B and C rooms must receive clean and sterilized
garments at each working shift. Gloves must be regularly disinfected during operations, as well
as the masks and gloves exchanged at each working shift.
17.6.10 The garments worn in the clean areas must be washed and cleansed to avoid the
release of contaminants in the areas where they will be worn. It is convenient to have a laundry
uniquely for this kind of garments. Garments damaged by usage may increase the risk of
releasing particles. The cleaning and sterilization operations must follow the Standard Operation
Procedures- SOPs.
17.7 Premises
17.7.1 All the premises must be designed in a way to avoid the unnecessary entrance of the
supervision and control staff. The grade B areas must be designed in a way that all the
operations may be observed from outside.
17.7.2 In the clean areas, all the surfaces exposed must be plain, impermeable, in order to
avoid the accumulation or release of particles or microorganisms, allowing the repeated
application of cleaning and disinfecting agents, when applicable.
17.7.3 In order to decrease the dust accumulation and to make the cleaning easier, in the clean
areas there must not be surfaces which may not be cleaned. The installations must have the
minimum of projections, shelves, cupboards and equipment. The doors must also be designed
in a way to avoid surfaces which may not be cleansed; sliding doors must not be used.
17.7.4 The coating must be sealed in a way to avoid contamination from the space above them.
17.7.5 The pipes and ducts must be installed in a way to avoid spaces difficult to clean.
17.7.6 The sinks and drains must be avoided, whenever possible, and there must not be areas
sinks and drains in the areas where aseptic operations are being performed. When their
installation is required, they must be designed, placed and maintained in a way to minimize the
risk microbial contamination, it must have efficient siphons, easy to be cleaned and appropriate
to avoid air and liquids refluxes. The ground drainage channels, if there is any, must be open,
easy to clean and be connected to external drains in a way that the introduction of microbial
contaminants is avoided.
17.7.7 The locker rooms in the clean areas must be designed as closed antechambers and
used in a way to allow the separation of the different garments changing steps, thus minimizing
the microbial contamination and particles from the protecting garments. Besides, the locker
rooms must be efficiently insufflated with filtered air. The use of separated locker rooms for
entry and exit may be necessary in some occasions. The premises designed to the hygiene of
hands, must be located only in the locker rooms, never where the aseptic operations are
performed.
17.7.8 The doors of the antechamber cannot be simultaneously opened, and there must be a
system to avoid this. There must be an alarm system, sonorous and/or lightening, alerting to the
situation mentioned above.
17.8 Equipment
17.8.1 The clean areas must have a ventilation system which insufflates the filtered air and
maintains a positive pressure of the area, compared to the surrounding areas. The ventilation
must be efficient and appropriate to the required conditions. Special attention must be given to
the areas presenting a higher risk, where the filtered air is in contact with the products and clean
components.
17.8.2 It may be necessary that the many recommendations related to the air supply and the
differential pressure are changed in case of the need to detain pathogenic materials, highly
toxic, radioactive materials or bacterial and live virus materials.
17.8.3 In some processes, it may be required the use of premises designed to decontamination
and the treatment of air leaving the clean area.
17.8.4 It must be shown that the air system does not constitute a contamination risk. It must be
ensured that it does not allow the dissemination of particles from people, equipment or
operations, to the production areas at higher risk.
17.8.5 An alarm system must be installed to indicate failures in the ventilation system. Besides,
a differential pressure index must be placed between the areas where this difference is
important. The pressure differences must be recorded.
17.8.6 The unnecessary access of material and people at the critic areas (grades B and C) must
be avoided. Whenever required, it must be done through physical barriers.
17.8.7 Transporting tracks interconnecting grade B clean areas to areas presenting an inferior
air classification grade must not be used, unless the track is continuously sterilized (e.g.: an
sterilizing tunnel).
17.8.8 The equipments used in the sterile products production, must be chosen in order to be
sterilized by steam, dry heat or other method.
17.8.9 Whenever possible, the equipment and utilities disposition must be designed and
installed in a way that the maintenance and repairing operations may be performed from the
outer side of the clean areas. The equipment that has to be removed for maintenance must be
sterilized again after they are reassembled.
17.8.10 When the equipment maintenance is performed into de clean areas, the instruments
and tools used must also be clean/disinfected. If the required cleaning and/or asepsis standards
are not kept during the maintenance service, the areas must be disinfected, so the production
may be restarted.
17.8.11 All the equipment, including sterilizers, air filtration systems and the water production
systems, must be subjected to a periodic maintenance plan, validation and monitoring. The
approval to the use of equipment must be documented, after the maintenance service.
17.8.12 The installations to be used for quality purified water production for injection must be
designed and maintained in a way to ensure the trustful production of water, of appropriate
quality. The system must not be operated beyond its installed capacity. The quality purified
water for injection must be produced, stored and distributed, according to the procedures
ensuring the maintenance of its characteristics, avoiding the proliferation of microorganisms.
17.9 Sanitization
17.9.1 The sanitization of the clean areas constitutes a particularly important aspect. These
areas must be frequently cleaned and sanitized according to a specific schedule approved by
the Quality Assurance. When using disinfectants, more than one kind must be used, with
frequent changes. Periodically, the management of the disinfectant used must be performed to
prove that there is not the development of resistant microorganisms. Viewing the limited efficacy
of ultraviolet radiation, it must not be used as a substitute in the chemical disinfecting
operations.
17.9.2 The disinfectants and detergents must be kept into previously cleaned containers and
must not be kept for long terms, unless they are sterilized. The partially emptied containers must
not be completed.
17.9.3 The fumigation of clean areas may be useful to reduce the microbial contamination into
inaccessible places.
17.9.4 The conditions of the clean areas must be monitored at pre-established periods during
the production operations, through the counting of viable particles in the air and surfaces
(microbiological). When aseptic operations are developed, the monitoring must be done more
frequently in to ensure that the environment is within the specifications.
17.9.5 The results of the monitoring must be taken into account when the batches are evaluated
for its approval. The quality of air in relation to the number of particles must also be regularly
evaluated. In some moments, when there is no production operation (after the maintenance,
validation, cleaning or fumigation processes) there might be the need of an additional
monitoring.
17.10 Production
17.10.1 Precautions must be taken in the sense of minimizing the contamination during all the
production steps.
17.10.2 The microbiological products with live organisms cannot be produced or filled in the
areas used for the production of other drugs. On the other hand, vaccines produced from
inactivated microorganisms or bacterial extracts may be filled, after their inactivation in the same
premises as other drugs, provided that the inactivation and cleaning procedures are validated.
17.10.3 The use of means of culture favoring the microbial growth in essays to simulate aseptic
operations (fillings with sterile means) constitutes an important procedure in the validation of a
aseptic filling process. These essays must present the following characteristics:
(a) they must simulate as faithful as possible the actual operations, taking into account factors
such as the complexity of operations, the number of people involved in the operation and the
term of filling;
(b) the mean selected must be able to promote the growth of a large number of microorganisms,
including those ones likely to be found in the environment where the filling process is performed;
(c) they must include the sufficient number of production units to check a high grade of safety
detecting lower levels of contamination. The inclusion of at least 3,000 production units is
recommended in each filling essay with the nutrient soap. The ideal growth percentage is of 0%;
and it must never be higher than 0.1% of contaminated units. All contaminations must be
investigated;
(d) the fillings with means of culture must be repeated at regular periods and every time there is
a significant change in the premises, equipment or process, a new validation must be done.
17.10.4 Care must be taken so the validation processes do not have a negative influence on the
production processes.
17.10.5 The activities developed in the clean areas must be as minimum as possible, specially
when aseptic operations are being performed. The people’s moves must be methodic and
controlled, with the purpose of avoiding the excessive loose of particles and microorganisms.
17.10.6 The raw materials specifications must also include requirements as for the microbial
quality. The microbial contamination of the raw materials must be minimum, and the bioload
must be monitored before sterilization.
17.10.7 The presence of containers and materials arising particles in the clean areas must be
reduced at a minimum and completely avoided when an aseptic work is being performed.
17.10.8 After the final cleaning or sterilization process, the handling of components, containers,
bulk products and equipment must be done in a way to avoid that they contaminate again.
Each step of the processing of components, containers for bulk products and equipment must
be properly identified.
17.10.9 The period between washing, drying and sterilization of components, bulk products
containers and equipment, as well as the period between sterilization and use, must be as
shorter as possible and it must be subjected to an appropriate limited time to the storage
conditions.
17.10.10 The period between the start of the preparation of a certain solution and its sterilization
or filtration through a bacterial retention filter, must be as short as possible. A maximum period
allowed must be established to each product, taking into account its composition and the
recommended storage method.
17.10.11 All the gas destined to help in the filtration or filling process of solutions must go
through a sterilizing filter.
17.10.12 The microbiological contamination of products (bioload) must be minimum before the
sterilization process. A maximum contamination limit must be established before sterilization,
related to the efficiency of the method that will be used and the risk of contamination by
pyrogenic substances.
17.10.13 All the solutions, specially large volume parenteral solutions must be filtered, by
sterilizing filters, if possible, immediately after its filling process.
17.10.14 When aqueous solutions are placed into sealed containers, the compensatory
pressure openings must be protected with hydrophobic filters which prevent the passage of
microorganisms.
17.10.15 The components, bulk product containers, equipment and/or any other articles
required in the clean area, where aseptic activities are being developed, must be sterilized and,
whenever possible, by double door sterilizers in the wall. Other procedures used with the
purpose of not introducing contaminants into the clean area, may be accepted under some
circumstances (e.g., triple cover).
17.10.16 Any new manufacturing procedure must be validated for proving its efficacy. The
validation must be repeated at regular periods or when significant changes in the process or
equipment are done.
17.10.17 The water provision sources, the water treatment equipment and the treated water
must be regularly monitored, as for the presence of chemical and microbial contaminants, and,
when applicable, a control for endotoxins (biological contamination) must also be performed, to
check if the water meets the appropriate specifications for its use. Records of the results of the
monitoring and measures adopted must be kept.
17.11 Sterilization
17.11.1 The sterilization may be done upon dry or humid heat application, gas agents, sterilizing
filtration with a subsequent aseptic filling of the final sterile containers, or by ionizing radiation.
Each method has its applications and specific limitations. Whenever possible and viable, the
method choice must be the sterilization by heat.
17.11.2 All the sterilization processes must be validated. The sterilization process must
correspond to the one stated in the technical report of the Product Registration.
17.11.3 Before the adoption of any sterilization method, its efficacy and adequacy must be
proven, so to the desired sterilization conditions are achieved in all the points of each type of
load to be processed. This validation must be repeated periodically, at least once a year, and
every time significant changes in the load to be sterilized or equipment is done. The results
must be recorded.
17.11.4 The biological indicators must be considered just as an additional method of monitoring
the sterilization processes. If they are used, strict precautions must be taken to avoid the
transfer of microbial contamination from them.
17.11.5 Clear means to differentiate the products and materials sterilized from the non-sterilized
ones must be established. Each container, tray or other kind of products or materials transporter
must be visibly identified with the material or product name, its batch number and the indication
if it was sterilized or not. When appropriate, indicators such as autoclave tape may be used, in
order to indicate if a certain batch was subjected to sterilization process or not. But, these types
of indicators do not provide trustful information proving that the batch was really sterilized.
17.12 Sterilization by heat
17.12.1 Each heat sterilization run must be recorded with appropriate equipment, accurately
and trustfully, (e.g.: time/temperature graphic with the a sufficiently broad range). The
temperature must be recorded from a lead-line placed in the coldest point of the sterilization
chamber. This point is determined during the validation process. The record system adopted for
the sterilization run must be part of the batch documentation. Chemical and biological indicators
may also be used, but they must not replace the physical controls.
17.12.2 Enough time must be given for all the load to reach the required temperature, before
the sterilization time measures are started. This time must be determined for each type of load
to be processed.
17.12.3 After the maximum temperature phase of the sterilization run by heat, the required
precautions must be taken in order to avoid the contamination of the sterilized load, during the
cooling phase.
17.12.4 No fluid or gas used in the cooling phase may be in contact with the sterilized product,
unless it is shown that any container presenting holes or micro-holes will not be approved for
use.
17.13 Sterilization by humid heat
17.13.1 The sterilization by humid heat is indicated in the case of materials permeable to water
steam and aqueous solutions. The temperature and pressure must be used to monitor the
process, the lead-line of the temperature indicator must be independent of the lead-line used by
the autoclave controller, and there must be a temperature indicator, which reading during the
sterilization process must be routinely verified, by comparison with the values obtained in the
graphic. If the autoclaves have a drain at the lowest part of the sterilization chamber, it is also
necessary to register the temperature of this position during all the sterilization process. When a
vacuum phase is part of the sterilization run, periodical controls on the chamber air-tightness
must be performed.
17.13.2 The sterilized materials to be used (when they are not products into sealed containers)
must be wrapped in materials which allow the removal of air and the enter of steam, and also
avoid the recontamination after sterilization. All the parts of the load of the autoclave must be in
contact with the saturated steam or with the water, at the required temperature and during all
the time established.
17.13.3 It must be ensured that the steam used in the sterilization meets the appropriate quality
to the process and does not contain quarantined additives which might cause contaminations of
the product or equipment.
17.14 Sterilization by dry heat
17.14.1 The sterilization process by dry heat must include the forced circulation of air inside the
sterilization chamber and the maintenance of a positive pressure, in order to avoid the entry of
non-sterile air. If air is inserted into the chamber, it must be filtered through a sterilizing filter.
When the sterilization process by dry heat is also used for the removal of pyrogenics, essays
using endotoxins must be performed as part of validation.
17.15 Sterilization by radiation
17.15.1 The sterilization by radiation is mainly used with materials and products sensitive to
heat. On the other hand, many drugs and some packaging materials are sensitive to radiation.
Therefore, this method must only be applied when there is no damaging effect to the product,
experimentally proved. The ultraviolet radiation is not an acceptable method of sterilization.
17.15.2 If the sterilization by radiation is performed through an agreement with third parties, the
manufacturer have the responsibility of guaranteeing that the requirements established are met
and that the sterilization process is validated.
17.15.3 During the sterilization process the radiation doses used must be measured. With this
purpose, dosimeters which are independent from the amount of dose applied and which
indicate the real amount of radiation doses received by the product must be used. The
dosimeters must be included in the load in a number sufficient and so close one from the others
that they allow to ensure that there is always a dosimeter in the radiation chamber. When plastic
dosimeters are used, they must be used within a time limit established after their calibrations, as
well as the values readings must be performed as close as possible of the radiation incidence.
The biological indicators may only be used as an additional control mean.
17.15.4 Colored disks sensitive to radiation may be used to differentiate the packages subjected
to radiation from the ones not subjected; These disks may not be considered as indicators of
sterility guarantee. All the information obtained during the process must be registered in the
batch documentation.
17.15.5 The validation methods of the processes used must ensure that the effects of the
ranges of the packaging material densities were considered.
17.15.5 The procedures for the handling of materials must ensure that there is no possibility of
missing irradiated products with non-irradiated ones. Each package must have an indicator
sensitive to radiations identifying the irradiated ones.
17.15.6 The total radiation dose must be applied for a pre-established period of time.
17.16 Sterilization by ethylene oxide
17.16.1 The sterilization method using the ethylene oxide must only be used when any other
method is viable. During the process validation, it must be shown that there are no hazardous
effects for the product and that the ventilation time is enough for the reactive gas and products
wastes are below the limit established as acceptable for the product.
17.16.2 It is essential the direct contact between the gas and the microbial cells. The nature and
quantity of packaging materials may significantly affect the process.
17.16.3 Before being subjected to the gas action, the materials must reach and maintain the
balance with the temperature and humidity required by the process. The time used in this
process must be considered to minimize the time before sterilization.
17.16.4 Each sterilization run must be monitored with appropriate biological indicators, an
appropriate number of them must be used, distributed over all the load. The information
obtained must be part of the batch documentation.
17.16.5 The biological indicators must be preserved and used according to the manufacturer’s
instructions and their performance must be checked through positive controls.
17.16.6 For each sterilization run, a record of the sterilization running time, pressure,
temperature and humidity inside the chamber during the process and the gas concentration
must be kept. The pressure and temperature must be registered on a graphic during the run.
The records must be part of the batch documentation.
17.16.7 After sterilization, the load must be stored in a controlled way, under ventilation
conditions, so the presence of gas waste and reactive products decreases to acceptable levels.
This process must be validated.
17.17 Filtration of drugs which may not be sterilized in their final containers
17.17.1 Whenever possible, the products must be sterilized in the final containers, specially by
humid heat sterilization. Some solutions and liquids which may not be sterilized in their final
containers, may be filtered to previously sterilized containers, through sterile filters, with 0.22
µm (or less) sized pores or presenting similar properties, to the retention of microorganisms.
The possibility of supplementing the filtration process with some heating phases must be
considered.
17.17.2 Filters which loose fibers must not be used. The use of amianthus filters must be
definitely excluded.
17.17.3 The filter integrity must be checked though an appropriate method (e.g., application of
the “bubble point” essay), before its use and immediately after its use. The time spent to filter a
known volume of a certain solution and the difference of pressure used must be determined
during the process validation. Any significant differences related to established standards must
be recorded and investigated. The results of these verifications must be written in the batch
documentation.
17.17.4 The filter must not affect the product, removing its active ingredients or adding other
substances.
19.2 - Glossary
The definitions presented below apply to the terms used in this Regulation. The same terms
may present different meanings, on another context.
Calibration
Group of operations establishing, under specified conditions, the relation between the values
shown by a measuring instrument, system or values presented by a measuring material
compared to the ones obtained with a correspondent reference standard.
Acceptance criterion
Criterion establishing the acceptance limits of the specifications of raw materials, products or
processes/systems, required to take the decision of accepting or not, related to a certain
sampling plan, when applicable.
Specifications
Document describing in details the requirements the products or materials used or obtained
during the manufacturing must meet. The specifications act as the base for the quality
evaluation.
Validation Master Plan (VMP)
Planning of all the validation activities with the purposes, procedures, deadlines and
responsibilities defined.
Production Process
Production of drugs from defined raw materials, in a single process or in a sequence of
processes, involving premises, personnel, documentation, and environment.
Validation Protocol
Company document specific for each activity describing the procedures to be performed in the
validation, including the acceptance criteria for approval of a production process or part of it.
Equipment qualification (EQ)
Collection of operations establishing, under specified conditions, that the results of the tests of a
certain equipment show that it presents the expected performance. The measuring instruments
and systems must be calibrated.
Installations qualification (IQ)
Collection of operations establishing, under specified conditions, that the installation of
equipment, utilities, weighing and measuring instruments and production areas, in the drug
manufacturing, were properly selected and are correctly installed, according to established
specifications.
Operational qualification (OQ)
Collection of operations establishing, under specified conditions, that the system or sub-system
presents the expected performance, in all operational bands considered. All the equipment used
to perform the tests, must be identified and calibrated before their use.
Validation report
Document where the records, results and evaluation of a finished validation process or system
are gathered.
Revalidation
Repetition of the approved validation process, that provides the guarantee that the changes
introduced in the process/equipment, according to the changes of procedures or periodical
repetition performed at scheduled periods, do not adversely affect the characteristics of the
process neither the product quality.
Choice tests/ worst case
A condition or collection of conditions comprehending the higher and lower limits of processing
and the respective circumstances, within the specifications of the Standard Operation
Procedures, presenting the higher possibilities of product or process defect, when compared to
the ideal conditions.
Validation
Documented act attesting that any procedure, process, equipment, material, operation or
system, really conduct to the expected results.
19.3 - General considerations
19.3.1 The validation is part of the Quality Assurance. The validation involves the systematic
study of the premises, systems, and processes with the purpose of determining if they perform
their function properly and consistently, according to the specified. A validated operation
ensured the production of uniform batches which meet the required specifications.
19.3.2 On the contrary of many GMP requirements, validation by its own does not improve the
processes. It may only confirm or not, depending on the case, that the process was properly
developed and the it is under control.
19.3.3 All the activities of product developing must be concluded with a validation phase, this
includes, specially, the manufacturing of products under clinical trial and when the large scale
production of products developed in pilot designs is started.
19.3.4 The validations performed during the development phase of the products do not
guarantee that all production processes are properly validated. Consequently, validation must
be discussed within a broader context, as an activity started during the development and that
continues until the large scale production.
19.3.5 The validation processes required the mutual collaboration of all sectors involved, such
as development, production, engineering, maintenance, quality assurance and quality control.
19.3.5 Validation allows:
19.3.5.1 To enhance the knowledge in the production processes and, thus, to ensure that the
processes are under control.
19.3.5.2 To decrease the risks of quality deviation.
19.3.5.3 To decrease the risks of the non-conformity to the established requirements.
19.3.5.4 To decrease the quantity of quality control tests in the in-process control steps and in
the finished product.
19.4 Types of process validation
19.4.1 Prospective validation
The prospective validation is a documented act, based in the execution of a previously defined
tests plan, showing that the new system, process, equipment or instrument, not in operation yet,
meets the functional specifications and performance expectations.
19.4.1.1 The prospective validation is performed during the product development step, through
the analysis of the risk of the manufacturing process, which is detailed in individual steps; these
steps, by their turn, are defined based on the previous experience to determine if they can
cause critical situations.
19.4.1.2 The critical points must be identified, evaluated as for their probability and extension,
and have their causes researched. The research plans are defined, establishing the priorities
and their final evaluation.
19.4.1.3 If, at the end of the validation process, the results are acceptable, the process is
satisfactory. If the results are unsatisfactory changes in the process must be searched until it
presents acceptable results. This validation form is essential to limit the risk of errors occurring
in the large scale production.
19.4.2 Concurrent or simultaneous validation
The concurrent validation is performed during the routine production. This method is only
efficient if the product development step resulted in the appropriate knowledge of the process
basis. The first batches of the industrial production must be monitored as broadly as possible.
The nature and specifications of the subsequent in-process tests and final tests are based in the
evaluation of the results of the mentioned management.
19.4.2.1 The concurrent validation, together with a analysis of trend including the stability
studies, must be performed with the appropriate extension along the product life.
19.4.3 Retrospective validation
Retrospective validation is a documented act, based on the revision and analysis of the
background records, attesting that a system, process, equipment or instrument, already being
used, meets the functional specifications and performance expectations.
19.4.3.1 The retrospective validation involves the verification of the past experience of
production, assuming that the composition, procedures and equipment keep unchanged; the
mentioned experience and the results of the in-process control and final control tests are
evaluated. The difficulties and defects registered in the production are analyzed to determine
the limits of the process parameters. A trend analysis may be performed to determine the
extension in which the process parameters are within the allowable range.
19.4.3.2 Obviously, the retrospective qualification is not, in itself, a guarantee measure of
quality, and it must never be applied to new processes or products. It can only be considered in
special circumstances, e.g., when the validation requirements are established for the first time
within the company. In this case the retrospective validation may be useful to establish the
priorities in the validation program. If the retrospective validation results are positive, this
indicates that the process does not require immediate attention and may be validated according
to the normal schedule.
19.4.4 Revalidation
The revalidation is required to ensure that the intentional or non-intentional changes in the
production process, equipment and environment, do not adversely affect the process
characteristics and the product quality. The revalidation may be divided into two broad
categories:
19.4.4.1 - Revalidation after any change may alter the product quality.
19.4.4.1.1 The revalidation must be performed when any changes which might affect the
manufacturing and/or standard procedure, influencing the performance characteristics
established for the product are introduced.
19.4.4.1.2 Each raw material, packaging material, manufacturing process, equipment, in-
process controls, manufacturing areas and utilities (water, steam, etc), must be evaluated by the
company validation group, which decides if it is significant enough to justify a revalidation and,
its extension.
19.4.4.1.3 The revalidation after the changes may be based on the performance of the same
tests and activities performed during the original validation, including the in-process tests and
the ones related to the equipment.
Some typical changes requiring revalidation are:
Raw material: changes in the physical properties, such as density, viscosity, granulometry and
type of crystal, which might adversely affect the process or product.
Packaging material: any packaging procedure change which might affect the product stability,
e.g., replacement of a plastic material for filling for a glass material.
Process: any change which might affect the subsequent steps of the process and the product
quality, e.g., mixing time, drying temperature and cooling procedure.
Equipment, including measuring instruments: any replacement, repair and maintenance which
might affect the process as well as the product;
In the production area and utilities: any replacement, repair and maintenance which might affect
the process as well as the product, e.g., repair and maintenance of the ventilation system might
change the environmental conditions and, consequently, its revalidation might be required,
specially in the manufacturing of sterile products.
When deviations are detected during the self-inspection or audit, or during the continuous
analysis of the process data trend.
19.4.4.2 Periodic revalidation:
The changes of process might occur gradually, even when experimented operators work
correctly, according to the established methods. Similarly, the excessive use of the equipment
might also cause gradual changes. The revalidation into scheduled periods is recommended,
including cases where no change is detected, considering the use of the equipment and
possible human errors.
19.4.4.2.1 The decision of implementing periodical revalidation must be based specially on the
background data revision, generated during the in-process tests and finished product tests, after
the last validation, with the purpose of checking if the process is under control. During the
revision of the background data mentioned, any bias of the collected data must be evaluated.
19.4.4.2.2 In some production processes, the following points must be checked in the
revalidation:
19.4.4.2.2.1 If there is any change in the formula, procedures, batch size, etc. If positive, if its
impact on the product was evaluated.
19.4.4.2.2.2 If the calibrations were performed according to a established schedule.
19.4.4.2.2.3 If the prevention maintenance was performed according to a established schedule.
19.4.4.2.2.4 If the Standard Operation Procedures (SOPs) were properly updated.
19.4.4.2.2.5 If the SOPs were implemented.
19.4.4.2.2.6 If hygiene and cleaning program were implemented.
19.4.4.2.2.7 If any change on the control analytical methods was performed.
19.5 Pre-requisites to the validation of a production process.
19.5.1 Before starting the process validation, the equipment used in the production and the
control instruments, as well as the formulation must be qualified. The drug formulation must be
studied in detail and qualified in the development step. This involved the pre-formulation
studies, studies on the compatibility of active principles and excipients, as well as the finished
product and the packaging material, stability studies, etc.
19.5.2 Other aspects on the production must be validated, including the utilities (water, air,
nitrogen, electrical power, etc.) besides the support operations, such as cleaning and
sanitization of equipment and premises. The appropriate training and motivation of personnel
are pre-requisite to a successful validation.
19.6 Approaches
19.6 There are two basic approaches to the process validation:
19.6.1 Experimental approach, which is applicable to the prospective and concurrent
validations:
19.6.1.1 Broad product test.
19.6.1.1 One of the most practical process validation, specially to non-sterile products, is the
final product test with a larger extension than the required by the routine quality control. It may
involve the broad sampling, much beyond the one used to the routine quality control and tests
according to the normal quality control specifications, and usually only for some parameters.
Thus, for instance, some hundreds of tablets may be weighed by batch to determine the dose
uniformity. Then, the results are statistically treated in order to check the distribution normality
and to determine the average weight standard deviation. The trust limits to individual results and
to the batch homogeneity are also estimated. A broad safety that the samples randomly
collected meet the requirements of the regulation is provided if the trust limits are met within the
compendia specifications.
19.6.1.1.2 Similarly, sampling and broadening tests may be performed in relation to any quality
requirement. Additionally, the intermediary steps may be validated the same way, samples may
be individually essayed to validate the mixing steps or granulation steps in the low dose tablets
production, using the content uniformity test. The non-visible particle, in parenteral preparations,
may be detected through electronic devices.
19.6.1.2 Process conditions simulation
19.6.1.2.1 The process simulation characteristics are mainly used to validate the aseptic filling of
parenteral products which may not be sterilized in their final presentation. This involves the vials or
vial-flasks with mean of culture under normal conditions, followed by the incubation and control of
microbial growth, the number of vials and vial-flasks contaminated must be less than 0.1%.
19.6.1.3 Choice conditions / worst case
19.6.1.3.1 The procedure choice to be validated must have as a priority the activities related to
the process capacity, e.g., the process capacity may operate with no difficulties when the
parameters are close to acceptable limits. The use of acceptance bands to the raw material
quality in experimental batches may make the estimation of the extension where the process is
still able to produce a final product meeting the specifications possible.
19.6.1.4 Process parameters control
19.6.1.4.1 The physical parameters of the process are monitored in normal production runs in
order to obtain additional information on the process and its trust. Additional devices sensitive to
temperature, installed in an autoclave or in a sterilization/depirogenization heater, allow to
perform a detailed study on the distribution of the heat to the many loads. Heat penetration
measures must be performed to the products for injection presenting a higher viscosity or
volumes above 5 mL. The equipment for compression and production of tablets equipped with
cells sensitive to pressure is useful to the collection of statistical data on the compression
uniformity and, therefore, on the weight uniformity.
19.6.2 Approach based on the background data analysis
19.6.2.1 In the approach based on the background data analysis retrospective validation
experiments are not performed, but, on the contrary, all the background data available related to
a number of batches are combined and analyzed together. If the production is being developed
with no difficulties during the period previous to the validation, the in-process tests data and the
product final tests must be statistically collected and evaluated. The results, including the
process capacity studies, bias analysis, etc., indicate whether the process is under control or
not.
19.6.2.2 The results and quality control and process records may be used, to the retrospective
validation. A careful revision of the graphics allows to estimate the process trust. A process can
be considered trustful if the data recorded are within the control limits and the individual results
range are stable.
19.6.2.3 Additionally, the information on the problems related to the product is also analyzed.
The process trustful is shown if, during a considerable time, there are no rejections, complaints,
returns, unexpected adverse reactions, etc. The process may be certified as retrospectively
validated if the statistical analysis results are satisfactory, and the absence of quality deviation is
documented. But, it must be emphasized that this approach is not applicable to the
manufacturing of sterile products.
19.6.3 Example of priorities to a production process validation program
Table 1
Type of process Validation requirements
New Process
All new processes must be validated before their
approval for routine production.
Routine process to the All the processes affecting the sterility and the
production of sterile environment of the manufacturing must be validated;
products specially the sterilization process.
Routine production for Low dose tablets and capsules containing highly active
the production of Non- substances: mixing validation and granulation related to
Sterile products the content uniformity.
Other tablets and capsules: validation of the operation of
tablets compression and capsules filling related to the
weight uniformity.
19.6.4 It may be noticed that, once prepared the previous batches control graphics, they
become a potent tool to the prospective quality management. The data to new batches are
recorded over the same graphics, and, for each result out the control limits, a reason for this
deviation is searched and once found, it must be eliminated. Applying this approach,
consistently during a certain period of time, the process may be considered satisfactory.
19.7 Organization
19.7.1 In the Organization chart of the company the responsibilities to the validation activities
must be established. For this purpose, the company Board, must designate a person
responsible for the validation activities (head of validation), who institutes a validation group
(team, committee). This group must have representatives of all the main sectors: Development,
Production, Engineering, Maintenance, Quality Assurance and Quality Control. The group
composition must be periodically renewed, in order to propitiate the opportunity for other people
to contribute with new ideas and to acquire experience. The group prepares a validation
program defining its priorities, schedule, required resources, etc. A program must be revised
and approved by the sectors involved. The final revision and approval are a responsibility of the
head of validation.
19.8 Scope of a process validation program
The priorities suggested for a validation program are related in Table 1. For new processes it is
recommended that the first three (3) industrial production batches are not released from
quarantine after their approval by the quality control, until their validation is concluded, the
results presented and revised and the process approved.
19.9 Validation Master Plan
The Validation Master Plan of a specific process, must contain, at least, the following topics:
1. Purpose (and previous requirements)
2. Presentation of the whole process and sub-processes, flow chart, critical points / risks
3. Organization structure of the validation activities
4. Reason for inclusion or exclusion from a certain validation
5. Tracking system for reference and revisions
6. Required trainings for a validation program
7. Type of validation defined for each system or project
8. Planning and chronogram of the activities to be performed
9. Cross-reference and other documents
The Validation Master Plan must include the cleaning procedures and analytical methods
validation.
ANNEX II
Evaluation Classification and Criteria to the items in the Inspection Guide to Companies
Manufacturing Drugs.
The criterion established for the classification is based in the potential risk inner to each item in
relation to the quality and safety of the product and worker safety in his/her interaction with the
products and processes during manufacturing.
INDISPENSABLE - I
The item considered INDISPENSABLE is the one that meets the Good Manufacturing Practices
recommendations, which might influence in a critical level the quality or safety of the products
and the safety of the workers in their interaction with the products and processes during the
manufacturing.
Defined by YES or NO
NECESSARY - N
The item considered NECESSARY is the one that meets the Good Manufacturing Practices
recommendations, which might influence in a less critical level the quality or safety of the
products and the safety of the workers in their interaction with the products and processes
during manufacturing.
Defined as YES or NO
The item NECESSARY not met in an inspection, will be consequently classified as
INDISPENSABLE in the following inspections.
RECOMMENDABLE - R
It is considered RECOMMENDABLE the item which meets the recommendations of Good
Manufacturing Practices which might influence in a non-critical level the quality or safety of the
products and the safety of workers in their interaction with the products and processes during
the manufacturing.
Defined as YES or NO
The RECOMMENDABLE item not met in an inspection, will be consequently classified as
NECESSARY in the following inspections. However, it will never be considered
INDISPENSABLE.
INFORMATIVE - INF
The item considered INFORMATIVE is the one that presents a descriptive information, which
does not affect the quality and safety of the products and the safety of the workers in their
interaction with the products and processes during the manufacturing.
It may be answered optionally as YES or NO, or descriptively.
ANNEX III
Inspection Guide to Companies Manufacturing Drugs
1.- MANAGEMENT AND GENERAL INFORMATION
2. -PREMISES
8.- PRODUCTION
8.4.3. Filling
8.4.4 Packaging
8.5.3.2. Labeling
8.6. Products of therapeutic classes requiring special production conditions in addition to the
requirements already established by the production line
8.7.3.- Area for the preparation of products with final sterilization or with sterilizing filtration
9. QUALITY CONTROL