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Chinese regulations
Issued Date 2006/11/13 Issued by BFDA Ref. No 0951401750 RE To announce the “Guidelines for Preparing a Plant Master File
(PMF)” Attachment “Guidelines for Preparing a Plant Master File (PMF)”
Official Letter from DOH
Date: 13th November 2006
Ref. No: 0951401750
RE: To announce the amendment to the “Guidelines on the Preparation
of PMF of International Manufacturers” and the “PMF Checklist for
Overseas Sites” (please refer to the attachments).
Contents:
I. The “Guidelines on the Preparation of PMF of International
Manufacturers” and the “PMF Checklist for Overseas Sites” were
amended and announced by the DOH on 10th February 2000 (Ref No.
89006528). The “Validation Requirements Checklist for Overseas Sites”
was announced by the DOH on 19th march 2002 (Ref. No. 0910021216).
II. From 1st May 2007, those who apply for PMF assessment for overseas
sites should conform to the amended “Guidelines on the Preparation of
PMF of International Manufacturers” and the “PMF Checklist”. During
the period from the date of the announcement to 30th April 2007,
applicants could choose to follow either the old or new version of the
Guidelines and Checklist.
III. If the plant is not able to provide the contents of the “L. Documents of
validation requirements” as specified in the “PMF Checklist”, the
applicant could apply for the assessment by submitting the CPP, an
overview of product validation and an official statement issued by the
plant. Detailed description of the required dossier is as follows,
(1) CPP: issued by A10 countries or by the EMEA in the past 2 years.
(2) Overview of the product validation: A summary of the execution of
all validation processes as listed in the “Guidelines on the
Preparation of the PMF” (including the validation of supporting
systems, such as ventilation (HVAC) system and water system,
facility/ equipment validation, computer system validation, cleaning
validation, etc). All data specified in the “notes” should also be
submitted.
(3) Official statement: The plant explains why they are not able to
provide the validation data in the “PMF Checklist” as required by the
DOH. The plant should state that the submitted data is sufficient
to prove the implementation of validation in the site, and
acknowledges the DOH’s right of site inspection. If necessary, the
DOH will follow international practices and carry out site inspection.
Guidance on the Preparation of PMF of International Manufacturers
I. Introduction
After the validation submission incorporated into the GMP Guideline in 1999,
the DOH announced the implementation of validation submission for
international and local manufacturers respectively. The validation submission
for local manufacturers has been fully implemented since 1st July 2004.
International manufacturers importing drugs from overseas also completed the
3‐stage validation submission by 10th December 2005. Since then, the
management of pharmaceutical plants enters the era of fully validated cGMP.
Concerning the assessment of PMF for the application of imported drugs, the
DOH announced the amendment to the “Guidance on the Preparation of PMF”
and the “PMF Checklist” on 10th February 2000, and announced the “Checklist
of Validation Submission for International Manufacturers” on 19th March 2002
(Ref. No. 0910021216). When submitting PMF for assessment, drug
companies could prepare the related data according to the aforementioned
two announcements. At present, the PMF contains data on validation
requirements, which include documents in relation to plant validation and
product validation.
Considering that the validation submission is a must for cGMP drug plant, it is
necessary to revise the current “PMF Checklist” so as to streamline the process
and satisfy the effective demands. Hence, the “Checklist of Validation
Submission for International Manufacturers” was incorporated into the “PMF
Checklist”. In addition, plant validation submission and product validation
submission are separated under the consideration of the practicality, the
improvement of assessment efficiency and drug associations’ comments.
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Some data on the plant validation submission is incorporated into the PMF
Checklist as well. The ventilation (HVAC) system validation, water system
validation, the facility/ equipment qualification, cleaning validation and
computer system validation are classified as PMF data. Process validation
and analytical method validation are parts of product validation and, therefore,
are not included in the PMF Checklist; they should be submitted with the
application of drug registration.
Also, data on stability tests, as part of quality control, is not included in the
PMF. This data is submitted with the application of drug registration. The
sterilization validation document and the document of the certification of
equipment for sterilization are incorporated into the process validation
assessment, and are too submitted with drug registration, because sterilization
is part of the manufacturing process. The authority hopes that the
amendment could simplify the preparation of PMF and expedite the
assessment process.
II. PMF should include the following items:
A. General information
A.1. Name of the plant
A.2. Full address (please specify, if the contact address and plant address
are different)
A.3. A brief introduction of the plant
Give brief information on the plant (including name and address),
relation to other sites and, particularly, any information in relation to
the manufacturing operation.
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A.4. Plant information
Give a brief description about the site (area, location, neighborhood
environment and other production activities on the site), operations on
the site (including pharmaceuticals and non‐pharmaceuticals), and give
a statement about whether some jobs are outsourced or whether
using outside technical assistance in relation to manufacturing and
analysis.
A.5. Type of products (including commissioning and commissioned contract
manufacture).
A.5.a. Activities approved by the competent authorities (photocopies).
A.5.b. List all type of drugs and their active ingredients manufactured on the
site (including commissioning and commissioned contract
manufacture). Local representatives shall edit the list and sort the list
according to dosage forms.
A.5.c. Specify any toxic or hazardous substances, such as antibiotics, hormone,
cytostatics, etc. Note whether the products are manufactured in a
dedicated facility or on a campaign basis.
A.5.d. In addition to drugs for human use, specify if the site also processes
drugs for animals, biological products, radioactive pharmaceutical,
diagnostic reagent, medical equipment, cosmetic or foods.
A.6. Dosage forms approved by competent authorities.
Local agent should fill‐in the dosage forms already approved by the
authorities and prepare official documents of the approval.
A.7. Dosage forms of application.
Local agents should fill‐in the dosage forms of application.
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B. Organization and Personnel
B.1. Organization chart and organogram and number of employees.
Organization chart, organogram and the qualifications, experiences
and duties of key personnel and the number of employees in
departments of manufacturing, quality control, storage and
distribution.
B.2. Basic and in‐service trainings for employees.
(Detailed descriptions or written SOPs are both acceptable.)
B.2.a A description of basic and in service training and the storage of training
records.
The description should include induction and continuous training, and
GMP related training and training methods (e.g. internal trainings,
external trainings, and how practical experience is gained, how
retraining needs are identified, etc). The description should also give
details about the establishment of the training plan, the evaluation of
training results and the system to store training records.
B.2.b. Related professional training for staffs responsible for sterilization
process (for sterile preparations).
B.3. Personnel hygiene regulation.
(Detailed descriptions or written SOPs are both acceptable.)
Give details about the regulations on pre‐employment medical
examination, routine medical examination, staff sickness report system
and additional health monitoring for staffs working in sterile areas, as
well as regulations on changing and cleaning of staff’s clothing.
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C. Premises and equipment
C.1. Factory premises plan.
C.1.a. A complete site plan (simple floor plan of all buildings on the site).
C.1.b. The allocation of manufacturing, packaging and storage areas and the
usage of each floor of the buildings.
C.1.c. A diagram of the flow and movement of employees, materials and
products.
C.2. A description of the ventilation (HVAC) system.
C.3. A description of areas with potential risks of airborne contamination
(schematic drawings of the system are desirable).
State the classification of the rooms used for the manufacture of sterile
preparations, penicillin, high toxic or hazardous substances, and
substances with risk of allergic reactions.
C.4. The system monitoring the environment of the manufacturing site (for
sterile preparations, penicillin, high toxic or hazardous substances, and
substances with risks of allergic reactions).
C.5. In areas for the handling of highly toxic, hazardous and substances with
risks of allergic reactions, is there a validated measure for the
prevention of cross‐contamination?
C.6. A description of the regular maintenance and testing operation of the
water system (Detailed descriptions or written SOPs are both
acceptable.)
C.7. Whether the premises of processing anti‐biotic are separated from
other areas. If the premises also process general preparations, the
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site should have a validated preventive measure for
cross‐contamination.
(narrative format)
C.8. The manufacturing, processing, packaging and sub‐packaging of
penicillin should be done in independent and exclusive premises and
facilities.
C.8.a. “Manufactured in independent premises” should be labeled.
C.8.b. Pressure differences of different areas should be labeled.
D. Facilities and equipment
D.1. A brief list of major manufacturing facilities (including processing,
packaging and storing).
D.2. Documents of the cleaning, calibration and maintenance.
(Detailed descriptions or written SOPs are both acceptable.)
Give a description of the regular maintenance arrangements and the
storage of records, facility quality confirmation (or validation) and
calibration (including recording system and arrangements for
computerized system validation), and written documents of
regulations on the cleaning of manufacturing premises and facilities
(including cleaning agents, cleaning procedures and result evaluation,
etc)
E. Documents of raw materials, final product containers, seals, labels and
packaging materials
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E.1. For raw materials, final product containers, seals, labels and packaging
materials, there should be detailed documents about the acceptance
examination, authentication, storage, handling, sampling, testing and
approval/ rejection. (Detailed descriptions or written SOPs are both
acceptable.)
E2. Each batch of raw materials is examined and checked with written
specifications. In cases of exemptions, QA or QC exemption
documents should be attached to state the procedures of acceptance
check, sampling, authentication, testing, quarantine, release and
storage of raw materials, final product containers, seals, labels and
packaging materials (including the identification of suppliers lot
number with the company’s lot number, sampling method, the
authentication and release). The disposal of rejected materials
should also be described.
(Detailed descriptions or written SOPs are both acceptable.)
F. Manufacturing process control
F.1. There should be written documents of process control and control
items in order to confirm that the key parameters, contents, quality
and purity meet the written specifications. (Detailed descriptions or
written SOPs are both acceptable).
F.2. General rules of manufacturing process control.
F.3. A description of the operational procedure of process control
according to dosage forms.
A flowchart of the major manufacturing steps of the dosage form of
application (e.g. filling of capsules, wet tablet press, direct press, liquid
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making, etc.). Major facilities and manufacturing control factors
should be specified, as well as in‐process check and the storage of
intermediate‐products (including semi‐finished products, sampling plan,
testing methods and the disposal of rejected products). Describe the
preventive measures for the processing of cytotoxic or radio‐active
substances in flow chart.
G. Quality control
G.1. List quality control equipment and equipment of laboratory quality
control equipment.
G.2. Documents of the responsibilities of QC related departments.
(Detailed descriptions or written SOPs are both acceptable.)
Give detailed description of the organizational structure,
responsibilities and duties of QC departments (including testing
methods of materials and products, and the establishment of
specifications, the assessment of batch records, quality control release
procedure and the assessment of the quality of supplied products, etc).
Describe the quality assurance regulations (e.g. specifications, testing
methods, and other information and inspection arrangements
associated with quality control) that ensure the effectiveness and
safety of products.
H. Changes of control
Specify the procedures for the alternation of the sites, facilities, equipments
and products and the changes in validation requirements.
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I. Contract manufacture and analysis
Documents about the GMP compliance of the contract acceptor.
I.1. State whether there is contract manufacture or analysis.
I.2. Describe the contract manufacture or analysis, or provide evidences
that the contractor has passed PMF assessment.
The general information of the site or company accepting the contract
manufacture or analysis (either full or toll‐manufacturing) should be
given. Documents of the GMP compliance of acceptors of the
toll‐manufacturing should be provided.
J. Distribution, complaints and product recall
Simple descriptions.
K. Site inspection and internal inspection
Simple descriptions.
L. Documents of validation requirements
L.1. Site validation policy.
Describe general policy for validation process
L.2. Facility and equipment validation.
Describe the following execution of the validation process
L.2.a. Supporting system.
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Specify the certification method and testing items of the ventilation
(HVAC) and water system and gas in contact with products (if any).
Provide the standards and the summarized qualification report.
L.2.b. Manufacturing premises/ facilities of the dosage form of application
L.2.c. Major manufacturing facilities of the dosage form of application
(including equipment and machinery facilities).
Attach a list of the 3Q certification reports of the manufacturing and
analytical equipment for the production of the dosage form of
application.
L.2.d. Computer system validation.
Attach a list of the computerized systems, specifying the types of
software and how to certify the reliability, stability and safety
(including a summary of the qualification results). Provide documents
of the authorization, backups, maintenance and calibration, control
changes, etc. (Detailed descriptions or written SOPs are both
acceptable.)
L.3. Cleaning validation.
Give details of cleaning procedures (by individual products or by
cluster), sampling plan (e.g. sampling point, sampling volume, sampling
diagram and sampling methods, etc), standards (including relevant
formula and descriptions) and a summarized qualification report
(including the adding and callbacks rate and blank assay). Attach the
summary of analytical method validation.
Note: If cleaning procedures are carried out by cluster, the methods of
forming clusters should be given. The active ingredients of
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products in each cluster and the indicator ingredients for cleaning
validation should also be listed
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