Benchmark Exel
Benchmark Exel
Address
Mfg Lic.no.
Validity of License.
Constitution of the firm
List of Directors/Partners/Proprietor
License issuing authority
Categories of drugs permitted to be manufactured
Specify whether COPP has been issued to the firm
Name and Designation of the Inspecting team members
Site Specific Data
No. of Products manufactured at site (during last year)
No. of manufacturing blocks
No. of Technical Personnel in Manufacturing
No. of Technical Personnel in QA
No. of Technical Personnel in QC
No. of Technical Personnel in Microbiology
No. of Technical Personnel from other Department
No. of Technical Personnel in R&D
No. Of technical personnel in Formulation development
No. of Samples drawn by QC (during last year)
No. of Samples declared OOS (during last year)
No. of samples declared NSQ by Govt. Analyst (during last year). Collect
reasons for such failures and annexe with this checklist
Observations should be descriptive without ambiguity and answer like "Yes" or "No" should be avoided
1 Building and premises: -
Observation
1.1 Sch-M, Specify whether the whole facility is separated,
dedicated and is not a part of any other non-drug
facility.
1.2 Sch-M, Specify whether the surroundings of manufacturing
area is clean and as per the SOP prescribed in this
regard. (Mention the SOP nos.)
1.3 Sch-M, Describe the pest, insects, birds and rodents control
system followed in the premises. Specify pest control
schedule- area wise, along with materials and
methods used.
1.6 Sch-M, Specify the air handling system used in various areas
i.e. stores, production, packing, QC areas.
2 Ancillary areas: -
2.1 Sch-M, Specify the position of rest and refreshment rooms
and mention whether they are separated and not
leading directly to the manufacturing and warehouse
areas.
2.2 Sch-M, Are there general change rooms in plant? specify
number of washing station & toilets provided for
number of users.
2.3 Sch-M, Specify whether primary clean garments are
provided for each personnel entering the factory
premises.
2.4 Sch-M, Is there in-house general laundry for garment
washing / cleaning? If not how garment washing is
carried out and monitored.
2.5 Sch-M, Para Whether change room facilities separated for both
sexes.
2.6 Sch-M, Para Whether maintenance workshop is separated and
away from production.
3 Security system:-
3.1 WHO TRS Is the men & material movement inside the factory
premises, observed & checked through security
system.
3.2 WHO TRS Is CCTV available to control the Entry & Exit from
Factory premises?
3.3 WHO TRS Is there a system for identifying persons visiting the
factory ? How?
3.4 WHO TRS What is the precautionary activity taken for the
movement of carriers i.e. vehicles?
4.1.1 Sch-M, Para Specify the MOC of the water storage tank (Both
PW & WFI) and its pipe line.
4.1.2 Sch-M, Para Specify weather storage tank for WFI is steam
jacketed.
4.7 WHO TRS- PHASE 2: Whether daily sampling records for every
970 pre-treatment point and usage point for a period of 4
to 5 weeks after Phase 1 maintained and reviewed.
4.8 WHO TRS- PHASE 3: Whether weekly sampling records available of every usage point for a one-year period.
970
4.9 Sch-M Specify source of raw water and give details of treatment processes, sampling points, distribution and storage system for r
4.11 Sch-M Specify whether the quality of potable water used for the
preparation of purified water meets the requirement of
Schedule M in respect of microbiological limit.
4.12 Sch-M Specify whether the quality of Purified Water used for the
preparation of WFI meets the requirement of IP/BP/USP.
4.17 Sch-M How bio burden in purified water & WFI are controlled / reduced (Mention the SOP no. followed in this regard).
4.17.1 Sch-M Specify whether WFI has been stored and circulated above 70 degree centigrade.
4.18 WHO TRS- Verify whether the circulation rate of purified water
970 & WFI is at least twice the storage capacity of the holding
vessels per hour.
4.19 WHO TRS- Verify the Dead leg of non returned valve at the discharge point.
970
4.2 WHO TRS- Specify how the circulation loop is sanitised. Verify the SOP.
970
4.21 WHO TRS- Specify whether spray ball is used to wet the surface of head space in the storage vessel.
970
4.22 WHO TRS- Specify whether pressure release valves are provided in the storage vessel.
970
4.23 Sch-M How water tanks are cleaned periodically and records maintained thereof.
4.24 WHO TRS- Specify whether on line TOC test is available for
970 WFI & PW.
4.25 PIC/S Examine the record of the daily check of balances in the
dispensing area.
4.25 Examine the record of the daily check of balances in the
Guidelines dispensing area.
4.26 Sch-M Specify the arrangement for preparation of pure steam &
its use.
4.31 WHO TRS- Specify whether action and alert limits are followed based
970 on qualification of water and compressed
Air system.
5.2 Sch-M Mention the procedure for storage and disposal of rejected drugs and applicable SOP.
5.3 Sch-M Whether adequate records are maintained for the disposal of waste.
6.3 Sch-M Specify whether employees report their illness to the supervising authority before entering into the production area.
6.4 Sch-M Specify whether person from infectious disease is barred to enter into production area.
6.5 Sch-M Specify if any unhygienic practise is observed within the manufacturing areas.
6.6 Sch-M Whether all personnel are trained to ensure high level of
personal hygiene. Mention the SOP no. followed in this
regard.
6.7 Sch-M Specify whether cross over bench is in place in the change
room and if so whether it rules out the possibility of dust
particle entering the clean side.
7.2 Sch-M Specify whether specific training related to the job duty are
provided to all personnel at the time of induction.
8 Warehousing Area:-
8.1 WHO TRS- Is access to the area restricted to authorised personnel only.
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8.4 WHO TRS- Is there any SOP defining maximum exposure time at
986 room temperature for thermo labile materials i.e. prior to
storage in a refrigerator.
8.6 WHO TRS- Verify the Thermal mapping of the cold rooms or deep freezers
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8.7 Sch-M Whether receiving and dispatch bays are maintained to protect in coming and out going materials.
8.8 Sch-M How incoming materials are treated and cleaned before
entry into the plant.
Please specify the cleaning system for the outer surface of
the container.
8.1 Sch-M Specify the system followed for storing passed raw materials.
8.11 Sch-M Whether proper racks, bins and platforms have been provided for the storage.
8.12 WHO TRS- What is the control on entry of material and men into the sampling area? Whether reverse LAF have been provided for sa
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8.13 Sch-M Specify the storage arrangement provided for primary packaging materials.
8.14 Sch-M Specify the arrangements provided to sample the primary packaging materials foils, bottles, etc. which are used as such.
8.16 WHO TRS- Which type of sampling tools are used and how they are cleaned, dried and maintained.
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8.17 WHO TRS- How containers are cleaned before and after sampling. (Specify whether the sampling is carried out as per the current SOP
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8.18 Sch-M What provisions have been made for segregated storage of rejected, recalled or returned materials or products. How is the
8.19 Sch-M How printed secondary packaging materials are stored in safe, separate and in secure manner.
8.2 Sch-M How printed packaging materials, product leaflets etc. are stored separately to avoid chances of mix- up?
8.21 Sch-M How labels, cartons, boxes, circulars, inserts and leaflets are controlled. ?
8.22 Sch-M How records of receipt of all labelling and packaging materials are maintained.
8.23 Sch-M Whether unused packaging materials return to the store or destroyed.
8.24 Sch-M How returned/unused packaging material like foils is controlled so as to prevent contamination and cross- contamination.
8.25 Sch-M Specify the arrangement provided for dispensing of starting materials.
8.26 WHO TRS- What is the control on entry of material and men into the dispensing area? Whether reverse LAF have been provided for d
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8.27 WHO TRS- Whether pressure differential is maintained between the dispensing and adjacent areas.
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8.28 WHO TRS- Specify the pressure differential maintained.
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8.29 Sch-M Examine the record of the daily check of balances in the dispensing area.
8.3 WHO TRS- How containers are cleaned before and after dispensing. Who carries out the dispensing?
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8.31 WHO TRS- Specify whether appropriate air velocity is maintained in sampling & dispensing areas which rule out any influence in the
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8.32 Sch-M Specify whether the dispensing is carried out as per the current SOP.
8.33 Sch-M Specify whether dispensed material for each batch of final product are kept together and conspicuously labelled.
8.34 Sch-M What steps are taken against spillage, breakage and leakage of containers?
8.35 Sch-M How highly hazardous, poisonous and explosive materials, narcotics, and psychotropic drugs are handled and stored. How
9 Raw Materials: -
9.1 Sch-M Please specify the procedures followed for receiving and processing of in-coming materials (Starting materials and packin
9.2 Sch-M Whether first in / first out or first expiry principal has been adopted.
9.3 Sch-M How they are labelled and stored as per their
9.4 Sch-M Whether incoming materials are purchased from approved vendors.
9.8 Sch-M Whether each batch of a consignment is considered for sampling, testing and release.
9.9 WHO TRS- Whether all the containers of each batch of starting materials sampled for identification test.
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9.1 Sch-M Whether labels of raw material in the storage area have information like ;
number;
9.11 Sch-M Whether separate areas are provided for under test, approved and rejected materials.
9.12 Sch-M How the containers from which samples have been drawn labelled.
9.13 Sch-M Please specify the procedures by which it is ensured that the raw materials which has been released by the Quality Control
10.3 WHO TRS- Whether entry and exit doors, for materials and personnel, have an interlock mechanism or other appropriate system to pre
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10.4 WHO TRS- Specify the procedures for entry of maintenance people into the production area.
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10.5 WHO TRS- Whether the change rooms have an arrangement with step-over/cross-over bench.
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10.6 Sch-M Is there any cris cross flow of materials and men?
10.7 Sch-M Whether the premises and equipment are appropriately designed and installed to facilitate cleaning and decontamination.
10.8 WHO TRS- Specify the position of IPQC lab in the manufacturing area.
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10.9 Sch-M Specify whether non storage areas are used for storage of any material.
10.1 WHO TRS- Specify the provisions for storage of dirty, washed and cleaned equipment in process areas.
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10.11 Sch-M Specify how service lines are identified for nature of supply and direction of the flow.
10.12 WHO TRS- Whether service lines in production areas are through service pendants. If not, how they are placed so as to avoid accumul
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ppropriate
11.2 WHO TRS- Verify the SOPs for AHUs operation and cleaning.
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11.3 WHO TRS- Specify whether the facilities and premises have following
986 basic air-handling characteristics:
a) The absence of direct venting of air to the outside.
b) Whether the facility is maintained at a negative air
pressure to the environment.
c) The precaution taken to prevent the infiltration into the
core areas.
d) Whether appropriate air pressure alarm systems as well
as alert and action limit is provided.
e) The type of HEPA filters used in the HVAC
system
f) Whether the change rooms are supplied with same
quality of air as supplied to the working area. g) The
measures taken to prevent air flow from the primary
packing area to the secondary packing area.
11.5 WHO TRS- Specify the emergency power systems in case of power failure.
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11.6 WHO TRS- Specify whether recirculated air is used. If yes, specify the proportion of fresh air supplied.
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11.7 WHO TRS- Whether risk assessment study has been carried out in case of return air/ recirculated air system. Verify the records thereo
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11.8 WHO TRS- Specify what precaution has been taken during filter change of AHUs.
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11.9 WHO TRS- Whether all exhaust systems from the facility, including dust extraction systems, vacuum system exhaust, fluid bed drier e
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11.1 WHO TRS- Whether all exhaust points outside the building are located
986 as far as possible from air entry points, exit points and at a
high level, to minimize the
possibility of re-entrainment of exhaust air.
11.11 WHO TRS- Whether the return air ducts are checked periodically for dust accumulation.
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11.11 Sch-M Whether the dust collectors are located in a room maintained at a negative pressure.
11.12 WHO TRS- Whether the filters cleaning facility is maintained at negative pressure.
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11.13 WHO TRS- Whether records for safe disposal of all contaminated filters and dust are maintained.
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11.15 WHO TRS- Specify whether total No. of AHUs used to cover the whole production Area is commensurate with the requirements
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11.16 WHO TRS- Specify the Terminal Air Filter of various core areas.
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11.17 WHO TRS- Specify the no. of Air Change maintained in various core areas.
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11.18 WHO TRS- Specify the pressure balancing to segregate different areas.
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11.19 WHO TRS- Are the returns risers cleaned during Product
986 Change Over?
11.2 WHO TRS- Verify if the AHU's / HVAC systems have been shut down. If yes the reasons there of such as cleaning & maintenance &
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12 Cleaning Validation:-
12.1 Sch-M Is a validation performed to confirm cleaning effectiveness?
12.2 WHO TRS- Does the protocol define the selection criteria for products or groups of products subject to cleaning validation?
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12.3 WHO TRS- Is data produced supporting the conclusion that residues were removed to an acceptable level?
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12.5 WHO TRS- Specify whether the Validation Strategy include contamination risks & equipment storage time.
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12.6 WHO TRS- Whether Quality Control responsible of the sampling for cleaning verification?
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12.7 WHO TRS- Whether personnel engaged in cleaning, sampling etc. trained.
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12.8 WHO TRS- Specify whether acceptance limits been set for cleaning
986 verification and are based on following criteria:
1) Visually clean.
2) 10 ppm in another product.
3) 0.1% of the therapeutic dose?
12.9 WHO TRS- Specify whether detergent residues and degradation products are investigated during validation.
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12.1 WHO TRS- Whether validation records include : Recovery study data,
986 Analytical method, Acceptance Criteria, Swab recovery
test,
Signatures of the Quality Assurance Manager, Signature of
the employee in charge of cleaning verification from
Production and Quality Control.
13.2 Sch-M Whether the products not prepared under aseptic conditions are free from pathogens like Salmonella, Escherichia coli, Pyo
13.3 Sch-M If yes, pls give brief account of measures taken to assure freedom from pathogens.
13.4 WHO TRS- Verify whether handling of materials and products are carried out in accordance with the relevant
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13.5 WHO TRS- Specify Whether any deviation is approved in writing by a designated person and recorded.
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13.6 WHO TRS- Is there an approved SOP for In process check?
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13.7 WHO TRS- Is the personnel clothing clean, unstained & dust free, including shoes?
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13.8 WHO TRS- Is there a cleaning SOP for slippers or shoes that is being used in the manufacturing area?
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13.9 WHO TRS- Whether process hold time studies has been carried out for various stages of production
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14 Precautions against mix-up and cross-contaminations:-
14.1 Sch-M Whether proper AHU, pressure differential, segregation, status labelling have been provided to prevent mix-up and cross-
14.2 Sch-M Pls specify the areas of dust generation and mechanism involved in controlling the dust
14.3 Sch-M Do all the areas have their own independent air locks separately for men and material entry.
14.4 Sch-M What criteria of pressure differential has been set for production v/s adjoining areas.
14.5 Sch-M Whether processing of sensitive drugs like Beta lactam Antibiotics and Sex Hormones is done in segregated areas with ind
14.6 Sch-M Please specify what measures has been taken to prevent contamination of products with Beta Lactam Antibiotics, Sex hor
14.7 Sch-M What measures has been taken to prevent mix- ups during various stages of production.
14.8 Sch-M Whether equipments use for production are labelled with their current status.
14.9 Sch-M Whether packaging lines are independent and adequately segregated.
14.1 Sch-M How line clearance is performed. Whether records of line clearance is maintained according to appropriate checklist.
14.11 Sch-M Whether separate carton coding area has been provided or online carton coding is performed How carton coding procedur
14.12 Sch-M Please specify how temperature, humidity and air filtration are controlled in the areas where raw material and/or products
14.13 Sch-M How access of authorized persons to manufacturing areas including packaging is controlled.
14.14 Sch-M Whether separate gowning provision is followed before entering the core areas.
14.15 Sch-M Whether segregated secured areas for recall or rejected materials or for such material which are to be processed or recover
14.16 Sch-M Whether various operations are carried out in segregated areas.
14.17 Sch-M Are doors of all core areas closed at all times with interlock arrangements?
14.18 Sch-M Specify whether any SOP is followed to verify the effectiveness for prevention of cross contamination.
14.19 WHO TRS- Specify whether critical operations are carried out in closed system.
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14.2 WHO TRS- Specify the methods followed for product change- over.
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15 Sanitation in the Manufacturing areas:-
15.1 Sch-M Specify the cleaning procedure of the manufacturing areas and verify with the SOP in this regard.
15.4 Sch-M Verify the SOP & the records in this regard.
15.5 Sch-M Does the location facilitate cleaning of equipment as well as the cleaning of the areas in which they are installed?
15.8 Sch-M Specify in detail the procedure followed during product changeover.
16 Equipment: -
16.1 Sch-M Whether the equipment are designed aiming to minimize risk of error and permit effective cleaning and maintenance in or
16.2 Sch-M Whether all equipment are provided with log book.
16.3 Sch-M Please specify the procedures to clean the equipment after each batch production.
16.4 Sch-M Whether validity period for use after the cleaning of equipment is specified.
16.5 Sch-M Whether separate area is provided for storage of machine parts etc.
16.6 Sch-M Whether balances and other measuring equipments with appropriate range are available in the Raw Material stores & prod
16.7 Sch-M Specify material of construction of contact parts of the production equipments.
16.8 Sch-M Which types of lubricants are used in the equipment. Specify the quality and control reference No. of these lubricants
16.9 Sch-M Specify the procedures to remove defective equipments from production areas.
16.1 WHO TRS- Verify whether washing and cleaning of equipment are not a source of contamination.
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16.12 WHO TRS- Specify the procedures to clean the equipment after each batch production and verify with the SOP.
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16.14 WHO TRS- Specify whether the CIP / SIP system is qualified
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16.15 WHO TRS- Are there cleaning agent labelled with a catalogue no.
986 indicating that they were received through the warehouse.
16.16 WHO TRS- Are there records for preparation of cleaning agent?
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17 Produ ction Area fo
r Sterile Preparation
17.1 Building and Facilities:-
17.2 Sch-M Sch-M Specify the building is devoid of cracks especially in the Critical solutions preparation rooms, Filling rooms, Sealing room
17.3 Are the location of services like water, steam, gases etc. Such that the servicing or repairs can be carried out without any t
17.4 Sch-M Specify water lines pose any threat of leakage to the critical area
17.6 Sch-M Specify de-cartoning areas to remove outer cardboard wrappings of primary packaging materials segregated from the wash
17.7 Sch-M Specify whether particle shedding materials like wooden pallets, fibre board drums, cardboards etc. are taken into the prep
17.8 Sch-M Specify in the classified areas:
1) Walls are flat, smooth and devoid of recesses.
2) Surface joints like electric sockets, gas points flushed
with walls.
3) Joints in the ceiling are properly sealed
4) Air grills and lights flushed with the ceiling.
5) Grade A & B areas devoid of sinks and drains.
6) Doors and windows made up of non shedding materials.
7) Doors open towards higher pressure areas and close
automatically due to air pressure.
17.16 WHO TRS- Is there a glass panel between critical area & support area so that all operations in Grade A & B areas can be supervised fr
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17.17 WHO TRS- Fire extinguishers are suitably fastened to the walls without gaps.
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17.18 Sch-M Quality of the furniture used is smooth & washable and made of SS316.
17.19 Sch-M Change rooms entrance provided with air locks before entry to the sterile product manufacturing areas.
17.2 Sch-M How many change rooms are provided to enter into the critical areas?
17.21 WHO TRS- Specify an appropriate inter- locking system with visual and/or audible warning system installed to prevent the opening of
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17.22 Sch-M Are the critical and support areas provided with intercom telephones or speak phones for communication purposes.
17.23 Sch-M Specify the critical areas and support areas provided with suitable air- locks or pass boxes with proper interlocking arrang
17.24 WHO TRS- Specify whether dynamic pass box is used for material transfer between two different air class.
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17.25 Sch-M Specify the method of transfer of sterile rubber bungs & aluminium caps to the aseptic area.
17.26 Sch-M Specify whether grade A/B area is devoid of sinks and drains.
18.2 Sch-M Give the Background Grade of air for following critical
areas:
1) Aseptic filling area
2) Sterilized components unloading area for aseptic filling.
3) Batch manufacturing area for aseptic filling
preparations.
4) Component washing and preparation area.
5) Change rooms to enter into Critical area.
18.3 WHO TRS- Specify the steps taken in air handling system to achieve the Grade A, B, C and D of air as per designated classified areas.
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18.4 Sch-M Specify the recovery time of B & C zone from the time of personnel leaving the room after completion of operations and
18.5 Sch-M Specify whether filling operations are challenged initially and there after periodically by simulation trials including sterile
18.6 WHO TRS- Specify the procedure followed for medial fill and the acceptance criteria.
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18.7 WHO TRS- Whether the medial fill trial is based on worst case situation taking into consideration all interventions, activities occurring
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18.8 WHO TRS- Whether simulation tests are repeated at defined intervals and after any significant modification to HVAC system, equipm
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18.1 Sch-M Specify the air velocity maintained in Grade A Laminar Air Flow stations
18.11 Sch-M Specify the differential pressure between areas of different environmental standards.
18.12 Sch-M Specify type of manometer installed for measurement and verification of Air Pressure Differential.
18.13 WHO TRS- Specify the air classification in final change room to enter A/B area.
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19 Environmental Monitoring:-
19.1 Sch-M Specify the temperature and humidity maintained in the critical areas.
19.2 WHO TRS- Verify the area qualification records and specify whether
961 the following were taken into consideration :
1) No. of Persons
ANNEXE-06 2) ACPH (Air Changes per hours)
3) Particle count (Static & Dynamic)
4) Viable count (Static & Dynamic)
5) Temperature & Humidity
6) Air Sampling location and interpretation of results
(Both viable and non-viable)
7) Whether the above method is in compliance with ISO
14644-1
8) Action and Alert limits for all the above parameters
19.5 Sch-M How long the settle plates are exposed in Grade A
and other areas.
19.6 Sch-M Verify the records of microbiological results also specify whether alert and actions limits are followed or not.
19.7 Sch-M What action is taken in case particulate and microbiological monitoring counts exceed the limits?
19.8 WHO TRS- Specify what parameters are reassessed and approved before starting production and in case of major engineering modific
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20 Garments:
20.6 Sch-M Are the gloves used made of latex or other suitable plastic material
20.9 Sch-M Are the foot-wear used made of plastic or rubber material
20.11 Sch-M Does the safety goggles / numbered glasses worn inside the critical areas have side extensions
20.12 Sch-M Are safety goggles sanitized by a suitable method
20.14 Sch-M Specify whether operators are trained in garment changing procedure.
20.15 Sch-M Specify a full size mirror been provided in the final change room to ascertain that the operator has appropriately attired in
20.16 WHO TRS- Specify how the garments used in clean areas are cleaned and sterilized.
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21 Sanitation:
21.1 Sch-M Specify the SOP followed for sanitation of sterile processing facilities and mention the SOP nos.
21.2 Sch-M Specify whether employees carrying out the sanitation of critical areas are specially trained for this purpose.
21.5 Sch-M Specify the quality of water used for preparation of sanitising solution.
21.9 Sch-M Specify whether fumigation is carried out in critical areas. If yes, specify fumigating agent and its conc. used.
21.1 Sch-M Specify whether any SOP exist for the purpose of fumigation if so mentioned the SOP nos.
21.12 WHO TRS- Specify whether particle monitoring in Grade A zones is undertaken for the full duration of critical processing including e
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21.13 WHO TRS- Specify whether particle monitoring in Grade B zones is undertaken for the full duration of critical processing.
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21.14 Sch-M Whether more than one sanitizing agent is used in rotation. If yes list the sanitizing agents their concentration and frequen
22 Equipment:
22.1 Sch-M Specify whether the unit- sterilizers are double ended with suitable inter-locking between the doors.
22.2 Sch-M Specify the initial effectiveness of sterilization process established by using microbial spore indicators.
22.3 Sch-M Specify whether thermal Mapping of heat sterilizers is carried out on regular basis. Check records.
22.4 Sch-M Specify suitable vent filters and recording thermographs provided in autoclaves & dry sterilizers.
22.5 Sch-M Specify HEPA filters for cooling air and recording thermographs provided in DHS/Tunnel.
22.6 WHO TRS- Specify whether provisions of CIP or SIP are available.
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22.8 Sch-M Specify filter integrity test carried out before and after the filtration process.
22.9 Sch-M Specify the material of construction of the equipment & glass containers.
22.12 WHO TRS- Verify the qualification, protocol and reports for the critical equipment.
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22.13 Sch-M Specify SOPs available for each equipment for its operation and cleaning.
22.14 Sch-M Specify whether the measuring devices attached to equipment calibrated at suitable intervals.
22.16 Sch-M Specify whether calibration status documented and displayed on the equipment and the gauges
23 Manufacturing Process
23.1 Sch-M Specify whether the bulk raw materials and bulk solutions monitored for bio-burden periodically (solutions not to contain
23.2 Sch-M Specify the minimum possible time between the preparation of the solution and its sterilization or filtration through micro
23.3 Sch-M Specify the porosity of the filters when any external gases are coming into contact with the sterile product.
23.4 Sch-M Specify whether gas cylinders are kept out side of the critical areas.
23.7 Sch-M Is each lot of the finished product filled in one continuation operation?
23.8 Sch-M Specify whether all critical process is validated. Verify the records.
23.9 WHO TRS- Verify the process validation protocol and reports for the critical operation.
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23.1 WHO TRS- Specify whether critical operations are carried out in closed system.
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24. Aseptic processing and sterilization by filtration:
24.1 Sch-M Specify whether the filling area is of Grade A
environment with Grade B background.
24.2 Sch-M Specify the room classification of solutions preparation area which is sterilized by filtration.
24.3 Sch-M Specify the filter used for sterilization of solution by filtration.
24.4 WHO TRS- Specify the maximum possible time used for filtration process.
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24.5 Sch-M Specify whether integrity of the sterilizing filters is verified before and after use. If so, by which method.
24.6 WHO TRS- Specify whether the personal working in the aseptic area are qualified for clean room procedure or not. If so verify the trai
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25.2 Sch-M Specify whether Specifications, Test methods, Cleaning procedures, Sterilizing procedures etc. are available of the contain
25.3 Sch-M Specify whether the container & closures are compatible with the product without affecting its quality and purity. Verify t
25.4 Sch-M Specify whether containers and the closures are finally washed with WFI before sterilization.
25.5 Sch-M Specify whether a written procedure exist for washing of glass ampoules/vials.
25.6 Sch-M Specify whether the material quality of the stoppers and closures ensures that it does not affect the quality of the product a
26 Sterilization
26.1 Sch-M Whether the sterilizing processes have been validated (Dry heat, Moist heat, filtration, ETO, ionizations whichever applica
26.2 Sch-M Whether the validity of the process verified at regular intervals (at least annually)
26.5 WHO TRS- Verify that the probe is placed at the coolest point on the basis of validation studies
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26.6 WHO TRS- Verify the qualification, protocol and reports for the sterilisers
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26.7 Sch-M Whether the biological indicators stored and used as per manufacturers instructions. Whether quality
26.8 Sch-M
26.9 Sch-M Whether the label on the basket / tray or other carrier of
product / component clearly states:
26.1 Sch-M Whether sterilization records including thermographs and sterilization monitoring slips attached with the Batch Production
27.2 Sch-M Whether the position of temperature probes used for controlling and / or recording determined during validation and (whe
27.3 Sch-M Whether the chart forms a part of the batch record.
27.4 Sch-M Whether sterilization cycle validated only by biological indicator and chemical indicators or physical validation is also car
27.5 Sch-M Whether the time allowed reaching the required temperature before commencing the measurement of sterilizing time, sepa
27.6 Sch-M Are adequate precautions taken to protect the load during cooling after it has gone through the high temperature phase of a
27.7 Sch-M In case the cooling is affected with any fluid or gas in contact with the product , is it sterilized.
27.8 Sch-M Whether the equipment air inlet and outlets been provided with bacteria retaining filters
27.1 WHO TRS- Verify the sterilizer loading pattern & whether is complied with the validated loading pattern.
961
ANNEXE-06
28.1 Sch-M Whether recording of both temperature and pressure carried out to monitor the process
28.2 Sch-M Whether the control instrumentation independent of the monitoring instrumentation and recording charts.
28.4 Sch-M Whether the system and cycle faults are recorded inbuilt and also observed by the operator and record maintained.
28.5 Sch-M Whether the readings of the thermograph during sterilization cycling are routinely checked by the operator against the read
28.6 Sch-M Whether the sterilizer fitted with a drain at the bottom of the chamber If so, does the record of temperature at this position
28.7 Sch-M Are frequent leak tests conducted on the chamber of the autoclave on each day of operation.
28.8 Sch-M Whether all items to be sterilized (other than sealed containers) are wrapped for sterilization.
28.9 Sch-M Whether the wrapping material allows removal of air and penetration of steam ensuring contact with the sterilizing agent a
28.1 Sch-M Whether the wrapping prevent contamination after sterilization
29. Others
29.1 Sch-M Specify whether products released only after complete filling and testing.
29.2 Sch-M Specify whether result of the tests relating to sterility, bacterial endo-toxins are maintained in the analytical records
29.3 WHO TRS- Whether process hold time studies has been carried out for various stages of production
961
ANNEXE-06
30.2 Sch-M How the documents are designed, prepared, reviewed and controlled to provide an audit trail.
30.3 Sch-M Whether documents are approved signed and dated by appropriate and authorized person.
30.5 Sch-M Whether documents are regularly reviewed and kept up to date.
30.6 Sch-M Whether the records are made at the time of each operation in such a way that all significant activities concerning to the pr
30.7 Sch-M Whether data is recorded by electronic data processing system or by other means. If by electronic data processing system
30.8 Sch-M Whether master formula and detailed operating procedures for each product are available?
30.9 Sch-M Specify the duration of retaining the documents after the expiry of the respective product and who is responsible for its ma
31.1 Sch-M Whether the printing is in bright colour and legible on labels and other printed materials?
31.2 Sch-M How printed labels (art work) are approved. Verify the SOP.
31.3 WHO TRS- Specify whether cut labels or rolled labels are used.
986
31.4 Sch-M Whether the labels comply with requirements of
Rule 96 & 97 & other relevant provisions
32.1 Sch-M How master formula records for each product are prepared, authorized and controlled.
32.2 Sch-M Whether master formula is batch size specific.
32.4 WHO TRS- Whether master formula record covered all the points as prescribed in WHO-TRS 986 & PIC/S guidelines
986
33.1 Sch-M Whether the BPR/BMR for each product is prepared on the basis of currently approved master formula.
33.3 WHO TRS- Whether BPR / BMR covered all the points as prescribed in WHO-TRS 986 & PIC/S
986
34.1 Sch-M Whether authorized packaging instructions for each product of various pack size and type are maintained and complied wi
34.3 Sch-M Whether packaging lines are independent and adequately segregated.
34.4 Sch-M How line clearance is performed. Whether records of line clearance is maintained according to appropriate checklist.
34.7 Sch-M Are the quantities of packaging materials verified against the amounts stated as dispensed from the warehouse?
34.8 WHO TRS- Specify the monitoring code (bar code, pinholes etc.) for final packing materials.
986
34.9 Sch-M Is the batch yield calculated immediately upon completion of packaging operation & prior to the introduction of a new bat
34.1 Sch-M Is the yield calculation independently verified by second individual and whether any significant deviation from accepted y
34.11 Sch-M Is any excess printed packaging material destroyed on completion of the batch?
34.12 Sch-M Is there a provision in the department for the separation of printed packaging material for destruction & rejected product?
34.14 WHO TRS- Whether Batch packaging record covered all the points as prescribed in WHO-TRS 986 & PIC/S
986
34.15 Sch-M Whether all the documents generated during packaging are attached with the Batch packaging record.
34.16 Sch-M Whether BPR are based on current master formula record.
36.3 Sch-M Whether the recoveries are added into the subsequent batches. If yes specify the procedures.
37 Finished Product:-
37.1 Sch-M Specify whether finished products are held in quarantine until their final release.
37.2 Sch-M Specify the storage arrangement of finished products after final release by QA
38.3 Sch-M Specify the procedure followed for approval/rejection of raw materials, packaging materials, intermediate products and fin
38.4 Sch-L1 Specify the arrangement provided to protect sensitive electronic balances from vibrations, electrical interference, humidity
38.5 Sch-L1 Specify the safety measures taken to avoid any accidental hazards in the QC department.
38.6 Sch-M Specify whether separate washing and drying area is provided for glassware
38.7 Sch-L1 Specify which grade of glassware is used in assay procedures and whether they are certified/calibrated. Verify the certifica
38.8 Sch-M Specify whether any particular test is outsourced. If so mention the name of laboratory and verify the contract made in this
39 Microbiology Lab
39.1 Sch-M Whether separate AHU's are provided for microbiological testing areas.
39.4 Sch-M Whether entry to the sterile area is through three air lock systems with separate exit
39.5 WHO TRS- Specify whether access in sterile area is controlled, and if so the system followed in this regard
986
39.6 Sch-M Verify the list of equipment used in the microbiological lab and also specify whether these are placed logically and functio
39.7 Sch-M Specify whether operators are trained in gowning procedures. Verify the training records.
39.8 Sch-L1 Specify the gowning procedure to enter the sterile area. Verify the entry and exit records.
39.9 Sch-L1 Specify the air class of sterile areas and whether pressure difference is maintained. Verify the records.
39.1 WHO TRS- Specify whether an environmental monitoring programme is followed with alert and action limit.
986
39.11 Sch-M Specify whether a documented cleaning and disinfection programme is in place.
39.12 WHO TRS- Specify whether a procedure for dealing with spillages in sterile area is in place.
986
39.13 WHO TRS- Whether separate areas provided for sterility testing, assay of antibiotics & vitamins and MLT in sterile area.
986
39.14 Sch-M Specify the type of workstations (LAF) provided in the sterile area.
39.15 Sch-M Whether double door autoclave is provided for transferring of materials from unclassified area to sterile area.
39.16 WHO TRS- Verify the area qualification document for sterile area.
986
39.17 WHO TRS- Verify the procedure for selection of sampling location and interpretation of results for environmental monitoring of steril
986
39.18 Sch-L1 Specify whether qualification of all equipment and instruments used in this department is covered under VMP.
39.19 Sch-L1 Verify the qualification document of major equipment like autoclave/incubator, hot air oven, refrigerator, LAF etc.
39.2 Sch-L1 Specify the Calibration procedure of temperature measurement devices used in autoclave and incubator. Verify whether it
39.21 Sch-M Verify the procedure for the handling and disposal of chemical and microbial waste.
39.22 WHO TRS- Specify the procedure followed to verify the validity of the test in case of antibiotic potency testing.
986
39.23 WHO TRS- Specify whether there is separate autoclave for decontamination.
986
39.24 WHO TRS- Specify whether the Vendors for dehydrated media is approved and qualified.
986
39.25 WHO TRS- Specify whether GPT is carried out for dehydrated media.
986 / IP
39.26 Sch-L1 Specify whether performance of culture media (recovery or survival maintenance) is carried out and the results meet accep
39.27 Sch-L1 Specify the source of procurement of reference culture and its maintenance.
39.31 Sch-M Whether firm has provided microbiology lab for MLT test for nonsterile dosage form. If no how this test is complied.
40.2 Sch-L1 How the reference standards are stored, evaluated and maintained.
40.3 WHO TRS- Specify whether authorized access system is followed for reference standards.
986
40.10 WHO TRS- Specify the procedure for review of test data &
986 calculations.
40.13 Sch-L1 Specify the procedure for storage and distribution of received samples to different analyst.
40.14 Sch-L1 Is there a maximum time limit for retention of sample in the laboratory prior to testing?
40.15 Sch-L1 Specify the procedure followed for preparation, consumption & destruction of volumetric solution. Verify the SOP and re
40.16 Sch-L1 Specify whether there is a log book for the preparations of the reagent including name of the analyst, name of the reagent,
40.17 Sch-L1 Specify the procedure followed for using GR, LR and AR grade of chemicals / solvents used for calibration & sample test
40.18 Sch-L1 Specify whether respective STP is followed by the analyst for analysis.
40.19 Sch-L1 Specify the procedure of reporting the result of analysis by the analyst to QC Head.
40.2 Sch-L1 Specify the procedure followed for storage of samples after testing.
40.21 Sch-L1 Specify the procedure for retention of samples after testing is completed.
40.23 Sch-L1 Specify procedures for safe removal of waste from the laboratory.
40.24 Sch-M Specify whether raw materials, intermediates and
finished product testing is carried out as per specifications and
raw data is maintained.
42 HPLC Calibration
42.1 IP Verify the records of calibration of following
parameters:
(GPV).
stop watch
44 UV-VIS
44.1 IP Verify the records of calibration of following
parameters:
visible wavelength
46 FTIR
46.1 IP
pa
47 TOC Analyser+
47.1 USP
pa
48 Stability Studies
48.1 Sch-M Specify whether stability study is carried out in the QC and if so, is there separate area for Stability Chamber for stability s
48.1 Sch-M
48.2 WHO TRS- Verify the qualification documents of all the stability chambers.
986
48.3 WHO TRS- Specify whether a written programme for ongoing stability determination is in place.
986
48.4 WHO TRS- Specify whether a complete description of stability study is available.
986
48.5 WHO TRS- Verify the stability calendar along with stability protocol and documents. Attach the copy of stability calendar
986
48.6 WHO TRS- Specify whether the stability protocol indicates complete set of testing parameters and methods.
986
48.7 WHO TRS- Specify whether summary of all generated data from the study are retained.
986
48.8 WHO TRS- Specify the testing schedule for each product
986
48.9 WHO TRS- Specify whether stability study is performed after any significant changes in process equipment, packaging materials etc.
986
48.1 WHO TRS- Specify the validation method for stability chambers
986
48.11 WHO TRS- Specify the Temperature and humidity for real times studies carried out for fixing shelf life of drug in the country.
986
49 Quality assurance:-
49.1 Sch-M Mention the documents prepared and maintained by QA department
49.4 Sch-M Verify the total list of SOPs maintained by QA and how QA ensure that no obsolete SOP is in circulation.
49.5 WHO TRS- Specify whether any procedure is followed for preparation of SOPs and its circulation to all concerned. How master, contr
986
49.6 WHO TRS- Mention the change control procedures & examine three recent change control forms.
986
49.7 WHO TRS- Specify the procedures followed to ensure CAPA process. Verify the SOP and three recent records in this regard.
986
49.8 WHO TRS- How deviation are controlled. Verify SOP and three recent
986 deviations. Specify whether all deviations
are reported and records maintained.
49.9 Sch-M Is the production batch record and release test results reviewed for accuracy and completeness before a batch/lot of finishe
results;
methods;
50.3 WHO TRS- Verify whether Cp and CpK values are calculated
988 and what is the acceptance criteria fixed.
51 Product Recalls:-
51.1 Sch-M Specify the product recall system.
51.2 Sch-M Verify the procedure followed to handle the
recalled products
51.3 Sch-M Are distribution records available for a prompt
recall of products from the market?
52.3 WHO TRS- Is CAPA process followed in response to each complaint documented?
988
52.4 WHO TRS- Specify whether system of route cause analysis is followed by the firm on the complaint of adverse drug reaction.
988
52.5 Sch-M Specify the review system for complaints concerning the quality of products.
52.7 Draft Rules Whether the firm has provided Pharmacovigilance department for analysing complaints of adverse drugs reactions resultin
52.8 Sch-M Are there any criteria for action to be taken on the basis of nature of complaint / adverse reaction?
53.2 Sch-M Whether quality policy has been included in the site master file.
53.4 WHO TRS- Verify whether all information as per WHO TRS
988 986 and PIC/S document.
54 Validation
54.1 WHO TRS- Specify the validation policy of the company
988
54.2 WHO TRS- Whether a Validation Master Plan has been prepared.
988
54.3 Sch-M Verify resources and those responsible for its implementation.
54.4 WHO TRS- Identify the systems and processes to be validated as per VMP
988
54.5 WHO TRS- Verify whether documentation, standard operating procedures (SOPs), Work Instructions and Standards (applicable for na
988
54.8 WHO TRS- Verify Protocol format for each validation activity, including re-validation and reasonable unforeseen events (power failur
988
54.11 WHO TRS- In case electronic data processing systems are used, are these validated?
988
54.12 WHO TRS- Please specify whether periodical challenge tests performed on the system to verify reliability.
988
54.13 Sch-M Are the validation studies performed according to pre-defined protocols?
54.14 Sch-M Is a written report summarized, results and conclusions prepared and maintained?
54.15 WHO TRS- Is the validity of the critical processes and procedures established based on a validation study?
988
54.16 WHO TRS- Are criteria established to assess the changes originating a revalidation?
54.16 Are criteria established to assess the changes originating a revalidation?
988
54.17 WHO TRS- Are trend analyses performed to assess the need to re-validate in order to assure the processes and procedures continue to
988
55.2 Sch-M Does a written SOP specify who shall conduct audits and qualifications (education, training, and experience) for those wh
55.3 Sch-M Does a written SOP specify the scope and frequency of audits and how such audits are to be documented?
55.4 WHO TRS- Specify whether record is maintained for CAPA on the basis of self quality audit / inspection and whether same is reviewe
988
56 Pharmaceutical Development
56.3 ICH/Q-8- Whether firm hires consultants for technology transfer. If so details thereof.
PICS
56.4 ICH/Q-8- Whether firm has adopted latest tools (quality by design) to develop new products.
PICS
57.2 ICH/Q-9- Whether firm has policy document on QRM. Specify document number and its effective date.
PICS
57.3 ICH/Q-9- Which known principles have been adopted to analyse risks e.g. FMEA, HAZOP, HACCP, FTA etc.
PICS
57.4 ICH/Q-9- Whether risk priority number (RPN) is calculated based on severity, probability and detectability. If so, what is the criteri
57.4 Whether risk priority number (RPN) is calculated based on severity, probability and detectability. If so, what is the criteri
PICS
57.5 ICH/Q-9- How many products, process etc. have been analysed for risk. Give brief.
PICS
58 Data Integrity
58.1 Sch-M Whether the records are completed at the time of the operation and are legible maintained with raw data if applicable.
58.2 Sch-L1 Whether the firm has software based manufacturing and testing equipment
58.3 Sch-L1 Whether the individuals are provided log in IDs for access. All login and logout information should be available.
58.4 Sch-L1 Whether rights to work, amend, modify, delete are specified in written document.
58.5 Sch-L1 Whether right to access and modify are with two different individuals. If yes how QA is involved in modification of data.
58.6 Sch-L1 Whether audit trails related to project creation (study creation), project (study) modification, deletion etc. are available.
58.7 Sch-L1 Whether the data is backed up at regular intervals. If yes what is the written back up policy. The data backup must be serv
58.8 Sch-L1 How Excel sheets are validated if calculation are done in Excel sheet.
58.9 Sch-L1 Whether the firm has QA SOP for review of data integrity or audit trail. If yes how the modification and deletions are revi
59.1 WHO TRS- Specify the management responsibility defined as per the quality manual
986
59.2 WHO TRS- Specify the Procedures followed for continual improvement of process performance and product quality
986
59.3 WHO TRS- Specify the performance indicators presently followed by the firm to monitor the effectiveness of PQS like product quality
986
59.4 WHO TRS- whether purchases are also included under PQS
987
59.5 WHO TRS- Specify whether life cycle approach is followed
986
59.6 WHO TRS- Give synopsis of last to management review meeting held by the firm
986
Critical Observations:
CLASSIFICATION
OF CRITICAL FINDING
S. No. Subjects Types of findings
1 Building and premises 1) The manufacturing facilities for potent drugs such as sex
hormones, beta-lactam and cytotoxic are common with
general drugs.
2) Some of the critical areas of manufacturing are exposed
directly with the environment
3) Pest infestation, rodents and birds found in the
manufacturing premises
4) No AHU is provided in the manufacturing areas where
raw materials and/or products are exposed.
2 Water and compressed air systems 1. Potable water was found outsourced without any
records / validation regarding any further treatment and / or
analysis before use.
2. WFI system and pure steam system of parenteral unit are ill
maintained and data in respect of their quality is falsified.
3. Purified water system is ill maintained and data in respect
of its quality is falsified.
4. Unfiltered gases used during filling of injectable or eye
preparations
5 Production area for sterile preparation Wide cracks on walls/floor/ceiling or fungal growth or cobwebs, or insects inf
6 Environmental Monitoring (Sterile preparation) 1. Suitable arrangements are not made for maintaining
temperature and humidity in critical areas.
2. The viable counts are not performed as per rules. The
microbial counts were found well above the limits however
reported within limits.
3. The HEPA filter integrity test (smoke testing),
particulate monitoring in air, air change rates tests are not
performed as per Rules.
9 Product Containers & Closures Recycled / second hand containers and closures are used for primary packaging
10 Others Batches failing initial sterility test are released for sale on the basis of a sec
.
QA
HR & QA
HR &QA
Engineering &QA
Storage
Area:
In storage
areas where
there is no QA
need for
detailed
visual
inspection or
reading, 2
Engineering &QA
HR & QA
HR,Engineering &QA
Engineering &QA
HR
HR
Engineering &QA
Engineering &QA
HR
HR
HR
HR
Engineering
Engineering
Engineering
Engineering &QA
Engineering &QA
Engineering &QA
Engineering &QA
Production, &QA
Production, &QA
Production, &QA
Engineering
Engineering
Engineering & QC
Engineering & QC
Production, &QA
Engineering &
Ptoduction
Production, &QA
QC
Engineering
Engineering
Engineering
Engineering
Engineering
Engineering
Production/Engineering
Micro/QC
Store
Store
Engineering
6
Micro/QC
QA
Engineering
Engineering
Engineering
Store
HR
HR
HR
HR
HR
7
HR
Production
Production
Engineering
HR
QA
QA
QA
QA
QA
HR
8
Engineering &QA
Store & Engineering
Store
Store
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
ON
DINGS
ACCONTABLE DEP.
ACCONTABLE DEP.
QA
QA
QA
QA
QA
QA
QA
QA
QA
HR
HR
QA
QA
HR
HR
HR
HR
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
Engineering &QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
QA
HR
HR
HR
HR
QA
QA
QA
QA
QA
QA
QA
QA
QA
HR
QA
QA
QA
QA