Agnes Artiges

Quality on the move at the EDQM
Lisboa
Lisboa,, 11 October 2004
Dr Agn
s Artiges
Agns
Director
Director,, European Directorate for the Quality of
Medicines - Council of Europe
A. Artiges, Lisbonne, 11/10/2004
Quality is never an accident.

It is always the results of high intention,
sincere effort, intelligent direction and
skillfull execution ; it represents the wise
choice of many options.
John Ruskin
AGENDA
Partnership European framework

Standardisation Ph. Eur.
Certification of suitability of monographs
for API
European Biological Standardisation
Programme
European OMCLs Network
EUROPEAN REGULATORY FRAMEWORK
Partnership EDQM-CoE/EU
EP Convention
1964: EU Observer
1975-2004: EU Dir, Reg. refers to EP
1994: EU signs the Convention
Contracts
1992: Biological standardisation
1994: setting up the Eur. Network of OMCLs
1997: EMEA post marketing control of centrally
authorised products
MISSIONS OF THE EDQM (1)
SECRETARIAT OF THE PHEUR COMMISSION

Goals of the Pheur:
- Harmonise the Q and the C of medicines for
human and veterinary use in Europe
- Contribute to the protection of Public health
- Promote free movement of medicines in
Europe
Activities based on an international
convention from the Council of Europe
Secretariat of Ph. Eur. Commission
Ph. Eur. MEMBER & OBSERVERSHIP

(including EU)
Purpose of a monograph?
Public standard
Independent evaluation of quality
specification
Applicable by all laboratories
Regulators need uniform quality standard
Sets standard for future products
The European Pharmacopoeia

Recent development
5th Edition (2004), general monographs

International harmonisation among JP, EP, USP
Functionality-related characteristics in excipient
monographs
Control of impurities in APIs
The Certification scheme
Electronic communication
10
General monographs 1.1

Cover classes defined by different criteria:
production method, origin, risk factors
Deal with aspects that cannot be treated in
each individual monograph
Residual solvents, polymorphism,
pesticides in herbals, etc.
11
Scope of monographs
Aim is to cover all sources of a product
approved for use in EP Member States
Monograph does not necessarily cover
other sources
Suitability to be demonstrated (CEP)
12
Ph. Eur.: Work Programme

Based on inquiries on needs of users
Licensing authorities
Industries, hospitals
Monographs
Pharmeuropa (4 issues/year)
Internet
Scientific seminar
13
Ph. Eur. and new technologies (1)

Products of Recombinant DNA Technology (5th Edition)
Alternative methods for control of microbiological quality
(Pharmeuropa No 16.4)
Cell & gene Therapy (Pharmeuropa No 16.4)
14
Ph. Eur. and new technologies (2)
Adenovirus vectors for human use

Plasmid vectors for human use
Poxvirus vectors for human use
Human haematopoietic progenitor cells
Gene transfer medicinal products for human use
Bacterial cells used for the manufacture of plasmid
vectors for human use (5.2.10)
Numeration of CD34 + cells in haematopoietic
products (2.7.23)
Microbiological control of cell therapy products
(2.6.27)
15
EDQM Laboratory
16
Publication of the Eur. Pharm. Texts (F+E)
5th Edition, updated 3 times a year (Book, CD-ROM

and Online versions)
A forum: PHARMEUROPA (4 issues per year) &
PHARMEUROPA BIO (2 issues per year) ;
An official guideline: THE LIST OF STANDARD TERMS
(pharmaceutical dosage forms, route of admin, containers) to be used in
MA dossiers (27 languages) ;
Technical guide for elaboration of monographs
17
5th Edition
18
Implementation dates
Adoption
Publication
Implementation
5 th Edition
11/2003
July 2004
Jan. 2005
Suppl. 5.1
03/2004
Oct. 2004
April 2005
Suppl. 5.2
06/ 2004
Dec. 2004
July 2005
19

Producing and distributing
Pharmaceutical RS , Biological RS
described in the standards
More than 1600 reference substances
available
20

Certification of suitability
of Ph. Eur. monographs
Participating in the European regulatory system by a centralised
evaluation of the quality that the quality of material is suitably
controlled by monograph (API & excipients)
Directives 2001/83/EC, 2003/63/EC & 2001/82/EC
21
How to demonstrate the suitability of

monographs for a substance ?
Improve up-date and transparency of
monographs
Procedure of centralised evaluation
elaborated with
The licensing authorities in Europe
Recognition of its validity
Industries -> assurance on the protection
of the information provided
Certification of suitability
22
Certification Unit
23
The CEP Steering Committee

Chairman of the Eur.Ph. Commission
Chairmen of technical groups
CPMP/CMV (QWP/BioWP/IWP/HPWP)
1 reprsentant enregistrement Etats non UE
1 reprsentant de lEMEA (Inspection)
1 reprsentant EDQM
Chairs of TAB
24
Certification - Inspection
Applicant to agree to be inspected
Inspection by national inspector + 2nd
from another country + EDQM
2 European inspectors outside Europe
1999 Pilot programme
2001 established inspection
48 sites inspected (18 in 2003, 7 in 2004)
25
Inspection
Inspection inside and outside Europe
Inspection of
Chemicals including sterile bulk
TSE risk
Manufacturers
Brokers
Authorities notified of issues arising

26
Certification: benefits
Single assessment
Uniformity of assessment
Replaces Drug Master File
Savings of time and cost
Updating of monographs (impurities)
Revision of monographs (new or
replacement test methods)
27

The European Biological Standardisation
Programme (BSP)
Goals
The establishment of European working standards;
The development and validation of new analytical
methods;
the validation of alternative methods in the
framework of the 3Rs concept (Refine, Reduce,
Replace animal experiments);
28
Recent achievements
Viral markers for blood HCVRnA, B19
Testing methods
Standard
Alternative methods
Tetanus
Diphteria/Serological methods
Hormones
Standards
EPO, IGg, Fact VIII/IX IG antiD
Established together with WHO,FDA

29

The European network of the Official
Medicines Control Laboratories (OMCL
network)
Created in 1994 in close collaboration with the E.U.
Goals of the OMCL network:
To develop exchanges and know-how, facilitate mutual
recognition of controls of national laboratories and
promote the future development of harmonised
common standards and foster further work-sharing.
30
Definition of OMCL
Public Institution which ONLY performs
laboratory testing for a Competent
Authority, independently from the
manufacturer, for medicinal products,
prior to and/or after marketing for the
general surveillance of medicines in
relation to the safety of human patient
and/or animals
31
OMCL Network: composition

OMCL Network is composed of public OMCLs and,
when appropriate, representatives of Competent
Authorities
Criteria :
establishing a formal QA System based on ISO
17025
Implementing European Pharmacopoeia
Indepency (see definition)
32
OMCL Network: objectives

Harmonise the administrative and
technical activities of common interests
Mutual recognition of national quality
control tests
OMCL tests samples of medicinal products
and/or its components to check whether
they comply with the specifications in the
MA application or in official documents
such as Ph Eur or specific guidelines
33
OMCL Network - Where are we ?

already in place:
Common QA system
Official Control Authorities Batch Release with
formal mutual recognition
Centrally authorised products
true work-sharing
34
OMCL Network - Quality Assurance

Development and maintenance of QA
system initiated in 1998
Implementation of QA System based on
Commonly agreed standard Iso 17025
Peer review (audit)
Specific procedures
PTS (performance measurements)
35
OMCL Network - Work-sharing

For techniques that are rarely used or
require on-going use
create centres of expertise
For other products cut costs by work-and
information sharing
for e.g. Mutual Recognition products (MRP)
36
MJA/MJV Programme
1999 - OMCL Network starts MJV/MJA system to help
each other implementing and maintaining a Quality
System
Standard ISO/IEC 17025 was selected
MJA are intended to evaluate the competence of the
labs in an equivalent way to the External
Accreditation Bodies
MJA/MJV highly appreciated - sharing of technical
knowledge, meeting other experts, independent
evaluation
37
MJA Process (1)

The interested OMCL makes an Audit request to EDQM Div. IV
5 types of Audit scope:
Blank audit (all elements covered, only recommendations
given)
Initial audit (all elements of ISO 17025 are assessed)
Surveillance audit (only specific topics are covered)
Reassessment audit (every 5 years, all elements covered)
Follow up of non-conformities
Audit team: one or more trained auditors from the OMCL Network +
audit team coordinator from EDQM (+ experts if needed)
Auditors sign a Confidentiality statement prior to the audit
OMCL is requested to send QS documentation for evaluation
38
MJA Process (2)
Audit Notification sent to the OMCL

Audit plan agreed with the OMCL
Audit check list based on ISO/IEC 17025
requirements
Closing meeting: findings are discussed with
OMCL Management
Draft Audit Report is sent to OMCL for comments
OMCL decides on corrective action + informs
Division IV on its status
When all non-conformities are solved, Div IV
sends a MJA Attestation
39
Tutorial Scheme
Tutors: qualified experts from the OMCL Network or from EDQM carrying out
tuition in the field of interest
Objective: to coach personnel on QA topics (general, specific,
implementation of the Quality system, etc)
TUTORIAL PROCESS
Interested OMCL makes a QA Tutorial request to EDQM Division IV
Coaching is given in the form of lessons, seminars, discussion groups,etc
Tutorial planning established by Division IV + QA Officer of OMCL
Tutors are bound by confidentiality agreement
Tutorial Report is written on site: topics discussed + recommendations
40
Proficiency Testing Studies

PTS
41
Proficiency testing
Proficiency testing is the use of inter-laboratory
comparison for the determination of laboratory
testing or measurement performance
Participation in proficiency testing schemes
provides laboratories with an objective means of
assessing and demonstrating the reliability of the
data they are producing
Use as a complement of the QA system in place as
requested by the standard ISO 17025
42
Some data
Scheme initiated in 1995 (OMCLs + EP lab)

Open to non OMCL labs since 2000 (2004
bio)
3-4 (bio) & 5-6 (physico-chemical)
studies/year
Average of 13 (bio) and 45 (physicochemical) participants/study
Use of compendial methods: EP, BP& USP
(for finished products only)
43
Physico-Chemical PTS Studies in 2004
Assay of tablets (UV-VIS)

RELS by HPLC
Water semi-micro determination
Assay of tablets (titration)
Chiral purity of essential oils by GC
Acetic acid in synthetic peptides
44
Physico-Chemical PTS studies for 2005
Assay of injections (HPLC)

Assay of suppositories (titration)
Residual solvents (GC)
Refractive index
Assay of tablets (HPLC)
Impurity profile
45
Physico-Chemical PTS programme

with WHO
Contractual collaboration with WHO since 2000

Programmes are run for a 1,5-2 years period
On going programme: 5 studies planned between
July 2004 and June 2006
42 control laboratories of the WHO regional offices
in Asia, Africa, South America, East Europe
Protocol based on IP & using essential medicines
46
Bio PTS Studies in 2004 (1)
PTS052: Testing human blood (plasma pools) for

contamination with B19 virus DNA by
quantitative Nucleic Acid Amplification (NAT)
1st PTS on topic (testing mandatory since 1/04)
Participation OMCLs and manufacturers
1/2 available test kits not appropriate
==> information of kit manufacturer
feedback to users of EP and regulators
47
Bio PTS Studies in 2004 (2)

PTS054: Testing human blood (plasma
pools) for contamination with
Hepatitis B RNA by qualitative NAT
Performed 1-2 per year
Significant decrease of number of
failing labs over time
First participation of manufacturers
48
Future Bio PTS studies 2004-5
PTS063: Endotoxin content of human

heparin preparations
PTS065: Serological potency assay of
acellular pertussis vaccines
HCV-NAT (as PTS054 but other virus
genotypes)
B19 NAT (as PTS052)
Pre-kallikrein activator content of human
albumin preparations
Anti-D immunoglobulin: potency assay
49
General activities
Market Surveillance Studies
MSS
50
MSS 2003/2004
MSS017 - Matricaria flower
MSS020 - Aciclovir tablets
MSS021 - Amoxicillin granules and powders
MSS022 - Ibuprofen tablets
MSS023 - Omeprazole tablets and capsules
51
MSS 2004/2005 (1)

MSS025 - Tablets for which subdivision is authorised
MSS026 - Erythromycin liquid preparations and
erythromycin esters preparations
MSS027 - Equisetum stem
MSS028 - Products containing sulfasalazines
Type of products: tablets / suppositories
Assay and impurity profile
MSS029 - Trimethropim
Control of impurities in API and tablets
52
EU/EEA EUROPEAN NETWORK OF OMCLs

OCABR
Common approach of batch release
Administrative procedure
39 guidelines product specific
mutual recognition
CAP (centrally authorised products)

Sharing sampling and testing
Reports to EMEA
53
CAP
Regulation 726/2004 & Sampling
and Testing Programme for
centrally authorised products
article 57r
54
Objectives of sampling and testing (1)

To supervise the quality of medicinal products
To confirm compliance of the medicinal product placed
on the market with its authorised specifications
To monitor the quality of the finished product in all parts
of the distribution chain throughout the authorised shelflife
To investigate suspected quality defects of CAPs -when
requested
To assist in testing of counterfeits of CAPs -when
requested
55
Objectives of sampling and testing (2)

To make use of existing systems and resources
To avoid duplication`
Provide for work sharing
Mutual recognition of testing results in the EEA
56
Organisational challenges
Partnership with EMEA/EDQM for cooperation with OMCL network
Support of GMP inspectors through ad hoc
GMP inspectors group
Dedicated EMEA staff member appointed
EDQM strenghtens coordination team
Regular feedback through Advisory Group
57
EMEA responsibilities
Responsible for choice of medicinal products
- adopted by scientific committees
Liaison with (co) rapporteur/working parties
Communication with Marketing Autorisation
holder
Co-ordination of communication of follow-up
measures
Overall responsibility
58
EDQM responsibilities
Coordination of EEA OMCL network

Organisation of QA system
Coordination sampling and testing
Receipt and reviewing of documentation
Reference material and specific reagent request
Define sampling and select inspectorates
Provide samples to selected OMCLs
Review and summaries results, report to EMEA
59
MAH responsibilities
Provision of documentation
Clarification of issues
Supplies of reference material/reagents
Pay for samples through voucher system
Explaining deviations
Implementing necessary follow-up
measures
60
National Authority Responsabilities

As (cooo) rapporteur/assessor - selection
of test and advising on implications of
outcome for dossier
As inspectors, sampling and taking into
account results in national inspection
programmes
As OMLC members, performing tests and
advising on outcomes
61
Examples of findings (1)

Products within specification limits
In some cases, difficulties in setting up the
test protocols
Problems in method transfer
Difficulty to fulfil system suitability criteria
Unclear descriptions in test methods
Incorrect or missing formulas for calculations
62
Examples of findings (2)

Questioning method sensitivity, precision
and robustness
Unclear specifications and impurity limits
Discrepancies between specifications and
referring analytical procedures
63
Origin of samples
Routine GMP-inspection of a contract
manufacturer
Observation of a major GMP-deficiency due
to insufficient testing of incoming APIs
Sampling of the API & Bulk and finished
product for analysis in OMCL
64
Conclusions
Working in a network: the 3C
Consultation
Collaboration
Co-ordination
65

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Quality on the move at the EDQM

Quality is never an accident.

A. Artiges, Lisbonne, 11/10/2004

Partnership European framework

EUROPEAN REGULATORY FRAMEWORK

A. Artiges, Lisbonne, 11/10/2004

MISSIONS OF THE EDQM (1)

SECRETARIAT OF THE PHEUR COMMISSION

Secretariat of Ph. Eur. Commission

A. Artiges, Lisbonne, 11/10/2004

Ph. Eur. MEMBER & OBSERVERSHIP

A. Artiges, Lisbonne, 11/10/2004

The European Pharmacopoeia

5th Edition (2004), general monographs

A. Artiges, Lisbonne, 11/10/2004

General monographs 1.1

A. Artiges, Lisbonne, 11/10/2004

A. Artiges, Lisbonne, 11/10/2004

Ph. Eur.: Work Programme

Ph. Eur. and new technologies (1)

A. Artiges, Lisbonne, 11/10/2004

Ph. Eur. and new technologies (2)

Adenovirus vectors for human use

A. Artiges, Lisbonne, 11/10/2004

MISSIONS OF THE EDQM (2)

Publication of the Eur. Pharm. Texts (F+E)

5th Edition, updated 3 times a year (Book, CD-ROM

A. Artiges, Lisbonne, 11/10/2004

A. Artiges, Lisbonne, 11/10/2004

MISSIONS OF THE EDQM (3)

A. Artiges, Lisbonne, 11/10/2004

MISSIONS OF THE EDQM (4)

A. Artiges, Lisbonne, 11/10/2004

How to demonstrate the suitability of

A. Artiges, Lisbonne, 11/10/2004

The CEP Steering Committee

Authorities notified of issues arising

MISSIONS OF THE EDQM (5)

EPO, IGg, Fact VIII/IX IG antiD

Established together with WHO,FDA

MISSIONS OF THE EDQM (6)

A. Artiges, Lisbonne, 11/10/2004

OMCL Network: composition

OMCL Network: objectives

OMCL Network - Where are we ?

A. Artiges, Lisbonne, 11/10/2004

OMCL Network - Quality Assurance

A. Artiges, Lisbonne, 11/10/2004

OMCL Network - Work-sharing

MJA Process (1)

MJA Process (2)

Audit Notification sent to the OMCL

A. Artiges, Lisbonne, 11/10/2004

Proficiency Testing Studies

A. Artiges, Lisbonne, 11/10/2004

Scheme initiated in 1995 (OMCLs + EP lab)

Physico-Chemical PTS Studies in 2004

Assay of tablets (UV-VIS)

Physico-Chemical PTS studies for 2005