Quality Audit
Quality Audit
Quality Audit
__________________________________________________________
1
Parul Institute of Pharmacy, Waghodia, Limda, Gujarat, India
2
Institute of pharmacy, Nirma university, Ahmedabad, Gujarat, India.
_________________________________________________________
ABSTRACT
Article Received on
15 October 2012, Quality audit is the process of systematic examination of a quality
INTRODUCTION
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examination and verification of activities, records, processes and other elements of a quality
system to determine their conformity with the requirements of a quality standard such as
USFDA and GMP.Any failure in their proper implementation may be published publicly and
may lead to a revocation of quality certification. Also called conformity assessment or
quality system audit.2
Medicinal products have to be of high quality as people lives depend on it, although end
product testing of samples from each batch is important, it is not enough to ensure quality
which must be built into the manufacturing processes.4 To ensure the quality, all
pharmaceutical manufacturers are required to establish and implement as effective
pharmaceutical QA system. To assess the effectiveness of these QA systems and to ensure it
follows GMP, self-inspection and other regulatory audits must be performed.3
Pharmaceutical manufacturers commonly use audits as an effective mechanism to verify
compliance with GMP regulation (GMP).
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Principle
Purpose of self-inspection is to evaluate the manufacturer’s compliance with GMP in all
aspects of production and Quality control. The self-inspection programme should be designed
to detect any shortcomings in the implementation of GMP and to recommend the necessary
corrective actions.11
Self-inspections should be performed routinely, and may be, in addition, performed on
special occasions, e.g. in the case of product recalls or repeated rejections, or when an
inspection by the health authorities is concerned. The procedure for self-inspection should be
documented.
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INTERNAL AUDITS12-15
Internal audits are carried out by an organization on its own systems, procedures and
facilities. Internal auditing involves the utilization of a systematic methodology for
analyzing business processes or organizational problems and recommending solution which
means vital from a business perspective. The organization of internal audits depends on
the size and complexity of the organization. A procedure and programme of internal
audits should be available.
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Tier One
Audits carried out by the staff of a section or department on themselves. Audits will
typically be short and limited in scope, focusing on 'visible', such as housekeeping and
documentation auditors are usually selected on the basis of knowledge and experience of
the area to be audited. Auditors should also receive some basic training on the reasons for
audits and particular areas for examination.
Tier Two
Audits typically carried out by a local QA group, comprising staff independent of the
department under audit. Such audits will typically be longer, but less frequent, and are
likely to focus more on systems than housekeeping.
More extensive audit training will be required for tier two auditors, with more detail on
quality systems and audit techniques.
Tier Three
Audits carried out by a corporate compliance group. Alternatively, external consultants
may be used. Such audits are often carried out to assess readiness for a regulatory audit,
but may also be used to obtain an expert view on a specific critical activity. Tier three
auditors are likely to be highly-trained and experienced specialists, with an expert
knowledge of GMP and other regulatory requirements for pharmaceuticals.
Increase the potential for early identification of regulatory concerns based on FDA
interpretations and current compliance focus.
Identify compliance deficiency and deviations from industry standards and company
requirements.
Provide a benchmark of compliance with other companies and regulatory
expectations.
Inform management of compliance status, regulatory risk, and civil liability.
Foster continuous improvement and forward quality.
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Provide a tool by which the company can stay ahead of rapidly increasing regulatory
demands.
EXTERNAL AUDITS16-18
External audits are audits carried out by a company on its vendors or subcontractors. There is
no legal requirement to conduct such audits. Need is implicit, since manufacturers are
required to have a thorough knowledge of their suppliers. Furthermore, if work is contracted
out, they must ensure that contractors are competent to complete it, in accordance with GMP.
There are also strong business benefits to be derived from performing these audits:
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The scope of these audits will vary, depending on the relationship between the two parties,
which may range from a simple vendor-purchaser transaction to a strategic joint venture
partnership. Regular audits will be carried out to assess compliance with agreed contractual
standards, the frequency of which will depend on the initial findings and the criticality of the
vendor and materials supplied.
External auditors typically have a broad practical experience of GMP and receive quality
systems auditing training equivalent to that of ISO 9001 lead auditors Audit teams may also
include specific technical experts, depending on the size of the facility and the scope of the
audit Many pharmaceutical industry suppliers are ISO 9001 or ISO 9002-certificated and
are regularly audited by their certification body
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The management shall discuss with the external auditors the overall scope of the external
audit, including
Identified risk areas
Any additional agreed-upon procedures
Review the external auditor’s compensation to ensure that an effective,
comprehensive and complete audit can be conducted for the agreed compensation
level.
REGULATORY AUDITS19-21
These audits are carried out by regulatory bodies against relevant regulations for the
manufacture and supply of pharmaceutical products. National regulatory bodies, such as the
Medicines Control Agency (MCA) in the UK and Food and Drug Administration (FDA) in
the USA, are statutorily responsible for carrying out such audits. These audits may be
unannounced (MCA currently performs about ten per cent of its UK inspections like this) as
manufacturers are expected to be complying with GMP at all times.
Regulatory bodies from other countries in which products are sold may also audit companies
(i.e. FDA audits European manufacturers).Regulatory inspectors are extensively trained and
are knowledgeable and professional. All MCA medicines inspectors are relevantly qualified
and have a minimum of five years' appropriate experience in a manufacturing operation; they
will be on the registers of persons eligible to act as qualified persons (QP) and lead auditors.
Failure to pass a regulatory audit can lead practical experience of GMP and receive to
restrictions on (or the withdrawal of) a manufacturing or import/export license
Currently, different regulatory bodies have distinct audit styles and requirements, but to
reduce costs and the audit burden on manufacturers, there have been moves towards sharing
and mutually recognizing audit findings between these bodies.
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Regulatory audits vary considerably in scope, frequency and duration. Audits by the national
regulatory body are likely to be regular and to cover systematically all areas of a facility, over
a period of time.
There may be additional audits (or visits) as a result of specific events, which may be
company-specific (for example, the recall of a product) or industry-wide (a recent example
being checks on compliance with transmissible spongiform encephalopathy’s regulations by
the MCA).Audits by the regulatory body of another country may be general or linked to a
specific regulatory event: The pre-approval inspections of the FDA are linked to submission
of a new drug application After a regulatory audit, a formal report will be delivered, the
format of which will depend on the regulatory body concerned: MCA provides verbal
feedback at the exit meeting, then a brief, action-orientated, written report shortly afterwards;
FDA provides a 'form 483' at the exit meeting.
What is to be audited:-
Auditors review SOPs to insure they are complete, accurate and appropriate for the
intended purpose Employee practices and behavior is observed to see how well they
follow established SOP’s. Compare master specifications against compendia and
regulatory requirements
Verify whether or not test data for in process and finished products confirm to
specifications whether validation testing has been performed for all pertinent
equipment and processed. Validation Test reports are compared against raw data and
documents are reviewed to determine if conclusions are supported. Verify corrective
actions taken in reaction to audit findings.
Deficient Practices that requires Regulation/or Administration:
1) Contamination or high potential for contamination with filth, objectionable
microorganism, toxic chemicals or other drug chemicals
2) Failure to assure that each batch conforms to established specifications
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GMP audits find objectionable condition that is unknown to responsible production, QC, QA
or management personnel.
For e.g. an auditor may observe an operarator at the aseptic filling machine, reaching over
exposed vials. Operator may not realize his/her actions were a source of potential
contamination
The auditor will see whether such actions are frequent or not .From this he can signal other
GMP problems.
Improper employee actions may result from SOPs not containing clear instructions
Inadequate employee training
Lack of adequate supervision
Audits can be effective mechanism to locate or identify problems which have gone
undetected during the normal Day-to-Day QC review. The detection of unknown or
unsuspected potential problems can be one of the most important benefits derived from an
audit programmed.
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a. If the problems are found , management takes an appropriate step to eliminate the
problem .A responsible management should also assess the likelihood that problems
may also exist in other systems and steps should be taken to correct the problems
b.An audit is not finding any objectionable conditions
Key Elements:
1) Expectations and Philosophies must be clearly defined by management
2) Audit Formats and Approaches
3) Checklist written criteria and Standard Operating Procedures
4) Planned Periodic frequency for audit
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Senior management establishes the fundamental expectations of audit and Upper level
management must establish the realistic goals and objectives. One practical approach is
use of “Formal Written Master Plan” approved by management. The master plan
defines in an organized and systemic manner which has responsibility for the audit
programme and Summary of documents represents overall philosophies and
Expectations for the audit programme.
Methods and Styles differ between companies and approach an audit differs by auditors
to auditor depending upon experience.
Manual GMP audit methods can be divided in two categories
1. Checklist format
2. GMP regulation approach
3. Systems analysis method
I. Checklist format:-
Pharmaceutical manufacturers commonly use checklist as GMP audit guides and
reporting finding. They are printed forms that have a series of questions or
instructions that are grouped in to logical order. Blocks may be used to record answer
and space may be provided to make comments. Questions on GMP requirements
covering at least the following items
Advantages:-
Simple, convenient and easy to use
May be used for any desired subjected area
Questions and guideline may be developed by knowledgeable personnel
Questions are in logical order that help auditor to detect problems
Report can be prepared in a minimum amount of time
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Disadvantages:
1) Interpreting Questions:
Inherent difficulties arise to develop questions that are clear (unambiguous).
Nearly every question may be interpreted in more than one way and auditor’s
actions or approaches may be influenced in unpredictable manner. Auditor’s
reaction will be determined not only by content of questions but also by factors
such as experience, knowledge of the subject matter, attitude and motivation
Checklist questions may introduce bias or have hidden meanings and care needs to
be that questions do not lead the auditor to answers that seem likely
E.g., have all master formula records been properly signed by a second person?
Did you find any instance where entries on the master formulas were not properly
signed by a second person? (Careful examination of records to find improperly
signed record)
2) Varied experience:
Devising Questions that are meaningful and informative for personnel with
different experience levels bias not an easy task. Clarity of the questions
determined by the extent of scientific and technical terms used. Questions must
be scientifically correct but should not be overly technical. Questions with too
few scientific terms may lead to ambiguous. Elementary Questions that are
helpful to inexperienced auditors may not be of much value to a senior auditor.
More complex or detailed questions useful to highly trained personnel may be
difficult to follow for those with limited knowledge of subject.
Inexperienced personnel may not fully understand the intent of questions or may
not recognize technical issues that are readily apparent to experience personnel
E.g., are sufficient procedures in place to assure product sterility when
sterilization cycled are interrupted? An inexperienced auditor may answer “yes”
after finding an approved SOP for resterilization and verifying that every load
during power failures had been resterilized per SOP requirement. Experience
Auditor responds “NO”: resterilization itself being objectionable.
3) Limited content:
The amount and type of questions that are provided limited. Not every issue will
be covered. Each auditor must apply sound judgment when evaluating system.
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Some firms audit systems by using GMP regulation as a guide. The basic elements
are derived from the following subpart of regulations:
Subpart B: Organization and personnel
Subpart C: Building and facilities
Subpart D: Equipments
Subpart E: Production and Processing Controls
Subpart F: Production and Packaging control
Subpart H: Holding and Distribution
Subpart I: Lab controls
Subpart J: Records and Reports
Subpart K: Returned and Salvaged drug
The language in GMP is not specific enough to serve as an audit.GMP regulation
contain broad statements of what is expected to be accomplished, but language doesn’t
use usually describe how it is to be done.
This approach involves systemic evaluation of the factors that are likely to affect
product quality. Formal assessments are made to determine whether or not conditions or
practices exit that may adversely affect assurance of product quality. This format
includes several variations depending upon the basic approach use to evaluate the
system. A number of FDA investigators are described the systemic audit techniques.
They emphasized the importance of establishing a basic set of criteria to evaluate the
cause and effect relationship of production and operations to final product quality.
These FDA investigators describe the organized method for determining of potential
problem may exist that may adversely affect the product quality.
3) Written criteria:
Formal written criteria need to be established defining which audit data or elements are to be
considered in the assessment of program performance
For audit data review these variables like
Reliability of vendors who supply raw materials
Components
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Services
Need to be identified and formal criteria established.
If criteria valid and complete, management can make sound scientific decision.
Effective use of written criteria to ensure that conditions and practices remain under a
suitable state of control.
Formal written SOPs should fully describe the details for carrying out the various audit
functions. The number of SOPs should be sufficient to represent each of the major audit
operations. SOPs should contain enough details to completely and clearly define what is
expected to be done and by whom.
5) Independent Responsibilities
The QA unit usually carried out the audit function if its primary responsibilities are clearly
independent from those of production and QC.
1) Announced Visits:-
Advanced notice is given before the audit.
It is not persuasive for two reasons:-
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The person makes major adjustment in their behavior in anticipation of audit. The
improved behavior may be temporary.
Reliability is diminished if the employee covers up the problem.
Benefits
Audit efficiency is improved from advance notification.
Necessary records may be organized and retrieved in the preparation for the
audit
Key personnel become available
2) Unannounced Audits:
Selected based
On their knowledge
Experience in manufacturing and QC principles as well as years of first hand
experience dealing with GMP matters.
Essential auditor skill is aware of
Firm’s SOPs and Knowledge
Integrated by various departments.
Minimum education requirements should be established to insure that auditors have
Sufficient technical knowledge to review
Educate complex systems.
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Two formats
1) Scientific Principles:-
Training under chemistry, engineering, statistical and pharmaceutics
2) GMP:-
GMP training may include the cumulative knowledge from years of
experience
This knowledge comes from
Formal training sessions
Daily activities
This approach is to prepare summary document showing
The nature
Level of training for the GMP elements
Team is required for major comprehensive audit that cover many different systems
and large amount of data. Composition of team will vary depending upon the nature
and scope of the audit. Persons having specialize experience or technical skill may
join the audit team. Leader is required for the auditing team who will assess each
member’s auditing skill. Leader will monitor their process at frequent intervals.
Leader is usually a senior auditor who has extensive knowledge of the firm’s
operations and exhibit strong leadership qualities.
Team size depends upon
1) Firm size
2) Total no of products manufacturing and control system
3) Breath and depth of the audit.
4) The Audit objective
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Audit report9, 14
Activity/Aspect audited:
Section: Report No:
Audit Officer: Date:
Details of activities ,documents ,methods , procedures ,records,
Results and reports examine during audit
Non-compliance(s): Category:
Corrective action(s)and time scale
(Officer responsible for action):
Noted and agreed on behalf of(section):
Signature of representative:
Corrective actions:
Carried out by(name):
On (date):
Confirmed by audit officer:
Signature:
On (date):
Received and approved by quality manager:
Signature:
On (date):
CONCLUSION
Quality assessment programs must faster and support continuous improvement and quality
performance. Nobody likes to be audited. It is a means to have continuous improvement. This
is especially when it involves giving your company the license to manufacture or shutdown.
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But, if a person is prepared and a functional quality system is in place, one can see it as a way
for continuous improvement.
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