COG - 0115 - The Guide To GXP Compliance
COG - 0115 - The Guide To GXP Compliance
COG - 0115 - The Guide To GXP Compliance
TO GxP
COMPLIANCE
CONTENTS
1. WHAT IS GxP? 3
The ‘X’ in GxP can refer to a number of disciplines - GMP (Good Manufacturing Practice),
GDP (Good Distribution Practice),GLP (Good Laboratory Practice) and many more.
Together they define the various ways companies in regulated industries are required
to control their processes, procedures, people and premises to ensure consistency and
quality in their products and services
The disciplines of GxP can also be relevant for those working in the
following sectors:
• Agritech
• Food production
• Novel food production
• Medicinal Cannabis Producers
• Cosmetics
For example:
Record Control
evidence that these tasks processes to achieve
have been performed required standards in
end products
• Create high performing products of consistent quality in the most efficient way
• Minimise risk of product failure - proportional to its potential to harm
• Provide evidence that regulated products are in conformity with
regulatory requirements
• Ensure knowledge is maintained in your organisation
• Establish a mechanism for communication in all levels of your company
• Achieve accountability across an organisation for regulated activity
GxP compliance is monitored and enforced by agencies and government bodies through
certification requirements, regular inspections and unannounced auditing.
In many cases the scope of the regulator’s remit continues to widen taking in new sectors
and product categories. This reflects the extent of innovation in these industries, as well
as cross-sector dependencies in the production techniques they use.
For this reason, regulators often require companies to verify and vouch for the GxP
compliance of their partners throughout the supply chain.
As a result more and more companies are finding they need to adopt GxP - and prove
they have adopted them - to protect their markets, supplier status and future business.
But all GxP can be seen as subsets of Good Manufacturing Practice (GMP) - because
they all feed into and support the safe production and delivery of regulated life
science products.
GxP is about controlling the processes by which these products are developed,
manufactured and handled in defined ways throughout the supply chain - ensuring they
are of consistent quality and can be used as intended by consumers:
To demonstrate that required controls have been observed and ensure potential
non-conformance in end products can be identified and corrected - there must be
accountability and traceability in data and documentation throughout the
product lifecycle.
Knowing that data and documentation is accurate, up-to-date and accessible (and that
they cannot be changed or tampered with) gives a high level of confidence to companies
and regulators. It tells regulators that required activity has been undertaken and
faithfully recorded by the right people at the right time.
Underpinning all GxP, therefore, are the record-keeping and documentation requirements
that keep processes trackable and companies fully accountable for the integrity of their
data and the quality of their end products. This is referred to by the FDA and others as:
It should be noted that GDocP is not a ‘standard’ in its own right, but is a key part of all the
practices described above.
To be compliant with GxP organisations need to specify, document and log every critical
action made by every employee in the development, manufacture and delivery of a
product or project by every employee. But they should do this in a way commensurate
with the risk that non-conformance poses. And in a way that is ultimately auditable.
To ensure all these required actions are understood and observed across an organisation,
companies need Quality Management Systems to be in place. These Quality
Management Systems need to:
Consequences of the breakdown of best practice include product failure, wasted time
and resource. But at the more serious end of the scale they include serious physical harm
to end users resulting in the revocation of licenses, major fines and even imprisonment
for those with liability.
Rules and interpretations differ from country to country (and change frequently) but all
GMP require that products
The 5ps of GMP - are the best practice areas of focus for life science manufacturers.
They prioritise reducing the risk of non-conformities in end products by ensuring the
consistent implementation of processes and procedures, equipment and personnel
training, across the product lifecycle.
P People
P
Premises & Equipment
P
Need to have clear roles and Are validated and calibrated for
responsibilities expected performance
Need to follow all procedures Have procedures, schedules and
records associated with them
Be fully trained and assessed
for the work they do Designed for effective cleaning
Products Designed to prevent cross
contamination
Have specifications for raw materials,
components, intermediate and
finished products
P P
Have repeatable methods for:
research, development, processing,
manufacture and packing, testing,
sampling, status control, stability
testing and record keeping
Processes Procedures
All critical steps identified Should be documented and recorded
All processes defined, consistent Cover all critical processes
and documented
Ensure all non-conformities are
Robust change controls are in place investigated and reported
GMP also sets out best practice methods for manufacturers to ensure their products are
packaged and labelled correctly, and that they have the ingredients and strength they
claim to have.
For a pharma production line controlled by computer systems much of the focus on
regulating quality of output shifts to the development and maintenance of the
software itself.
Construction
Factory Acceptance Test (FAT) & Site
Acceptance Test (SAT)
The V-model provides a logical sequence that helps to organise the complex activities of
defining a project scope, executing it, and qualifying it at every stage.
The V model provides an excellent basis for design control and tracking changes as a
project proceeds. And the right document management system can help companies
organise and generate the documentation required to execute and record this process
of specification, qualification and validation - with all the relevant files indexed and stored
for future auditing purposes.
What is GAMP5?
GAMP5® refers to the ISPE‘s best practice guidance (Version 5) which has been adopted
by the industry as a framework for companies to successfully validate their computerised
systems using a risk-based approach.
GAMP5 provides guidelines for required validation processes that take into account the
following concepts:
Adopting a Document Management System that functions as part of your QMS, can help
a business verify and validate the operation of its required functionality while creating
software systems. They can trigger validation processes to take place when new features
are added, which are automatically documented as part of your change control process.
Defining and setting up these systems early on will help companies more successfully
pass audits and inspections that increasingly focus on validation as a proactive measure
against systems and product failure.
In the UK, the MHRA inspectorate have explained how inadequate CSV documentation
frequently contributes to companies failing their audits:
“Many of these specific accounts point to a failure of systems and training when it
comes to documentation, with processes of validation being sketchily defined or
left half complete - pointing to a kind of process fatigue setting in at key moments
in a company’s evolution of best practice.”
Inspecting and certifying bodies around the world have echoed these issues.
ISO 13485 Clause 4.1.6, for example states that “software applications shall be validated
prior to initial use and, as appropriate, after changes to such software or its application”
A good supplier will be able to supply ‘validation packs’ to assist you in meeting these
application validation requirements.
Guidance on good clinical practice has been produced by the International Conference
on Harmonisation of Technical Requirements for Registration of Pharmaceuticals for
Human Use (ICH).
• All clinical trials should be conducted in accordance with ethical principles, sound
scientific evidence and clear detailed protocols.
• The benefits of conducting trials should always outweigh the risks.
• The rights, safety and well-being of trial participants are of primary importance
and these should be preserved by obtaining informed consent and maintaining
confidentiality.
• Care must be given by appropriately qualified personnel with adequate experience.
• Records should be easily accessible for accurate reporting, verification and
interpretation.
• Investigational products should be manufactured according to Good Manufacturing
Practice (2).
The ICH-GCP is a harmonised standard that protects the rights, safety and welfare of
human subjects in clinical trials. It seeks to minimise human exposure to investigational
products. In doing so it improves the quality of available data while speeding up the
marketing of new drugs and reducing costs for sponsors and end users alike.
The proper administration of PV within a business authorized to market and sell drugs
is vital to prevent the catastrophic failures of oversight experienced in the past, where
medicines such as Thalidomide continued to be licensed and sold, despite strong
evidence appearing of its horrifying side effects.
The QMS describes and defines all the measures, processes and procedures necessary
to ensure that suspected adverse reactions to medicinal products are collected,
processed and acted upon.
There are many requirements for the effective and auditable administration of this
system including:
• The preparation for the attention of the authorities of notification of serious adverse
effects (ICSRs), periodic safety reports (PSURs) and reports on studies of post-
authorisation safety (PASS);
GLP should govern studies around the hazards and risks to health and the environment
posed by:
• Medicines
• Pesticides
• Cosmetics
• Veterinary drugs
• Food and feed additives
• Industrial chemicals
A key objective of GLP is securing data integrity through Good Documentation Practice
(GDocP). GDocP ensures that regulated documentation is always accessible to those
who need it - as well as data that is, Attributable, Legible, Contemporaneous, Original and
Accurate (ALCOA+).
Adherence to these and other elements of GLP ensures that published data properly
reflects the results obtained during those studies and can therefore be relied upon when
making risk/safety assessments in development projects.
“an essential tool to secure the distribution system from counterfeits, unapproved,
illegally imported, stolen, counterfeit, substandard, adulterated, and/or misbranded
pharmaceutical products”
Regulators such as the EMA and the FDA have begun to increase focus on this area,
specifying the way processes and procedures should be implemented and recorded for
GDP compliance. In the UK, the MHRA certifies adherence to GDP through inspection
and auditing - and licenses businesses accordingly.
Operators in this sector need to have auditable systems that specify and define the
measures they take to ensure:
• Medical products are always transported and stored under the right conditions
• Contamination, theft or tampering is prevented
• Recalls and complaints can be effectively managed
• Only authorised products enter the distribution network
It should be noted that the number of critical dependencies within the supply chain
means that in the EU, distributors, manufacturers and their agents are now facing ‘ joint
and several liability’ for quality failings in end products. Manufacturers need to be
confident that their suppliers and distributors are implementing GDP in a trackable and
auditable way,
For all these reasons regulators around the world are increasingly requiring
distributors to have auditable Quality Management Systems that encourage
greater accountability, traceability and co-operation throughout the supply chain.
Digital QMS are needed to define and prove the GDP processes and procedures
distributors have in place to handle and deliver products in ways that ensure their
integrity and usability.
• All batches from each designated area should be unambiguously and unmistakably
identified by batch number.
• All processes and procedures that could affect the quality of the product must be
documented and used to promote best practice throughout the collection and storage
of the regulated materials
In recent years with the growth of interest in medicinal cannabis and as a legalised and
regulated ingredient in ‘novel foods’ - producers, distributors and manufacturers of
associated products are having to rapidly respond to new regulatory requirements.
One of the most challenging areas for these evolving companies - has been the
requirement to build the Quality Management Systems, with which they can document
and help implement best practice in an agile and auditable way.
All GxP have at their heart GdocP which allows for auditable and accurate record-
keeping, good governance and quality management.
For example, compliance with the Food and Drug Administration‘s GLP as well as GMP
regulations for drugs and medical devices (21 CFR Parts 211 and 820) all speak about the
observation of Good Documentation Practices.
• Protocols
ALCOA+
Data and documents must be
Data and documents must be
A ttributable Documents must clearly identify who has created and contributed to
them, and be protected against falsification or forgery of those details
A ccurate The processes and procedures by which companies record and keep
their documentation up to date must ensure accuracy and reliability.
+ Complete
All documentation
must have an audit
+ Consistent
Documentation must be
date and time stamped
+ Enduring
Data must be
available for as
+ Available
Data must not only exist,
they must be accessible,
trail to show no and stored in such a way long as the too, when and where
data has been to prove it has been regulation requires required for reference
deleted or lost. assembled in the and auditing purposes
expected sequence.
The definition and replication of all these GxPs across a business depends on the ability
to build a robust Quality Management System that is accessible to the people who need
to refer to it in their daily work.
A good digital Quality Management System can underpin a company’s ability to control
the administration and observation of GxP standards across a business.
The right digital QMS (with all its document control capabilities) gives workers the tools to
create and maintain a ‘single, accessible and definitive source of truth’ when it comes to
recording and implementing GxP in their working practices.
GxP COMPLIANCE
Establishes robust Defines and
and trackable documents SOPs Offers high level of digital
change control authentication as required
procedures by FDA 21 CFR Part 11
GxP compliance is about having the ability to implement (and prove you have
implemented) all the controls identified as necessary for the delivery of a reliable,
safe and usable end product or service.
Compliant businesses mitigate the risk of product failure (and, therefore, harm to
consumers) through consistent process definition, training, procedural control and
record keeping around all their working practices.
And this is the proactive approach to quality and risk management through the
implementation of best practice that notified bodies and regulators around the world
need to inspect, audit and certify.
But while you need a QMS robust enough to protect consumers against the risk of
product failure, your approach to GxP needs the flexibility to keep pace with new
commercial opportunities and legislative changes.
In the end, the accessibility and agility of the digital tools you use to manage
your quality management system will be pivotal to your successful and scalable
compliance with the regulation.
COMPANY INFORMATION
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E: [email protected] / T: +44 (0) 1223 911080