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5 OARO-Inspector's Eye -04 Feb 2017

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Pharmaceutical MicrobiologyMultidisciplinary Integrated Approach in Drug Manufacturing

Obaid Ali & Roohi B. ObaidCivil Service Officers, Government of Pakistan

5/5Inspections & Aseptic Processing Area

Managing an Aseptic Processing Area (APA)

Drug Product Sterilization Process Sterile Drug

Containers Sterilization Process

Sterile Container

Excipient Sterilization Process

Sterile Excipient

Closures Sterilization Process

Sterile Closures

Contact Surface

Sterilization Process

Sterile Contact Surface

Managing of all these steps is a real challenge for personnel

Working in an Aseptic Processing Area (APA)

Personnel

Knowledge

Ability

Skill

Atypical Job

Heavy gowning

Physical Exhaustion

Technical understanding

Very important

Educational background

K, A, S

Personal attributes

Grade A

Grade B

Grade C

Grade D

Process, Facilities

& Design

Personnel with

appropriate K,A,S

Training (Knowledge

based & performance)

Monitoring performance

Effective CAPAs

Aseptic Process

Connecting the Dots

Build Quality

Be proactive …. Rigorous thinking with logical, systematic &

science based approaches to improve effectiveness & efficiency of decision

making

Personnel & material flow

Air flow pattern evaluation

Aseptic operations

Disinfectant/ Sanitization

Cleaning efficiency

EM Plan

…… Inspector’s eyes looking for ……

Systems that allow inferior product to the market

Quality Management System

Production & Control Strategy

Potential adulteration boulevard

Consistency affairs

Contamination affairs

Identification & Traceability avenues

Reliability & reproducibility of results

Genuineness & accuracy of data

Validation Policy, Plan, Protocol, Report & Raw Data

Reports & Reviews

Developmental reports & Change Controls

Deviation, non-conformance, incidents

OOS, CAPA, OOT

Trainings & Effectiveness

Storage, Transportation

Human practice in aseptic areas

Sterility Failures

Media Fills

Rejects, Reworks, Re-process

Equipment repairing

Utilities & Plumbing Connections

Equipment logs

Maintenance Records

Cleaning Records

Observed Practice vs. Validated Practices

Personnel observed vs. Expected behavior

In-process store

SOP in place

Calibration stickers

Non-validated analytical methods

Growth promotion negative controls

Degree of product & process

understanding

Robustness of Quality System controlling the

process

Manufacturer’ ability to manage

risk associated with product

quality

Lets understand

GMP Inspection & Inspector’s Interest

Quality

Materials

Production

Laboratory Control

Facilities & Equipment

Packaging & Labeling

Quality

Review/approved procedure

Documentation of operation execution

Investigation Deviations

& Complaints

Failures

Production

Control Strategy

for change

Process validation

Investigation of

discrepancy

Missing & incomplete

records

In-process controls

Laboratory Control

Control Strategy

for change

Source of microbial

contamination

Investigation of

discrepancy Retention

of raw data

In-adequate sampling

Facilities & Equipment

Contamination

Cleaning procedure

Investigation of

discrepancy Equipment

qualification

Control strategy for

change

Materials

Identity test

Authenticity of COA

Investigation of

discrepancy

Control strategy for change in

handling of materials

Release of material

Packaging &

Labeling

Potential of mislabeling

Mix up potential

Investigation of discrepancy

Control strategy for

change

Packaging validation

Be Compliant and in state of Control

Aging infrastructure

Regular Assessment, Repair, Expertise, Risk Management

Conformance to Standards

compliant, competent in

microbial risk

assessment?

Culture

• Inherent human characteristic

Employee behaviors

• Absent or lagging change or behaviorDocumentation

• Expertise, Knowledge, CommunicationOversight

Key Compliance Root Cause Themes

• Human factorsEquipment design

• Appropriate, regularity, expertise & know-how

Equipment adjustment

• Risk Mitigation Activities absentEnvironment

Key Compliance Root Cause Themes

Lets sketch map

Lets count the dots to reconcile

Engineers design and

install

Validation department

executes validation

Production department performs

production

Maintenance department performs

maintenance

Quality Control performs tests

Quality Assurance

reviews and approves

Lets separate the dots to reconcile

Microorganisms unique to your

facility and operation

Personnel and material flow

Air flow pattern evaluations

Observation of aseptic filling operation

Environmental monitoring sample site selection