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Representatives to the PIC/S provide an example of methodology for implementing ICH Q9.
The International Conference on Harmonization guideline on quality risk management, ICH Q9, addresses active substances and medicinal products, and was adopted by the European Union and Pharmaceutical Inspection Cooperation Scheme (PIC/S) in Annex 20 of their good manufacturing practice (GMP) guides. Drug manufacturers are gradually implementing quality risk-management principles as introduced in sections 1.5 and 1.6 of the European Union's GMP Guide, Part I. However, the practical methods for these new requirements are still perceived as difficult to interpret and apply.
In this context, a small, informal PIC/S working group is developing an objective and pragmatic example of methodology for ICH Q9 that can be used by the widest audience. The methodology will meet the demands of operators and inspectors and comply with all regulatory requirements. The main axes of this methodology are presented in this article; a complete description with examples of how the methodology can be implemented is available on the PIC/S website (www.picscheme.org).
The methodology example is meant to be used for training and will not be issued as a PIC/S recommendation or guideline. The example will not influence the outcome of PIC/S inspections.
Primary methodological axes
The proposed methodology comprises an exhaustive review of the various stages that have an effect on the intrinsic quality of the product. These steps include:
For each recorded stage, risk is traditionally assessed according to potential severity and frequency of the risk occuring. The manufacturer's ability to detect risk and the experience gained in performing the step in question also help determine the risk involved.
Integrating a quantified experience factor in risk calculation with an objective scale serves as a major achievement in the field of risk management. Calculated in this manner, the level of evaluated risk expresses the degree of technical mastery acquired in the performance of each process step for the concerned perimeter, without having to take into account the specific characteristics of the products involved. This is the first phase of the methodology and has been named System Risk.
The second phase of the risk-management methodology considers the integration of the particular properties of the products themselves whose System Risk will have been previously assessed. This integration is done using a modulating factor, the P-factor, which, multiplied with the System Risk gives the Total Risk.
The P-factor takes into consideration the intrinsic physicochemical and pharmaco-toxological characteristics of the product as well as parameters expressing knowledge levels and experience gained by the manufacturer for the product concerned.
This dual approach makes it possible to significantly reduce the burden (i.e., resources) of risk management. For example, the methodology avoids the needless repetitions of risk-evaluation steps that are typically conducted during the introduction of a new product.
By implementing a risk-management policy that integrates the steps defined above, a manufacturer in the pharmaceutical area can maintain the relevance of its risk levels and evaluate them for a total risk calculation. A risk-management policy should also envisage provisions for the identification and inclusion of developments that could potentially modify the result of an initial risk evaluation. Such developments may be internal or external to the company and may or may not be integrated into the manufacturer's quality system.
Traditionally, these developments include the management of corrective actions and preventive actions, deviations, change control, and internal and external information (e.g., GMP modification). Finally, a company's methodology of risk management should be organized according to an iterative process.
Implementing the methodology
The PIC/S example of methodology provides pharmaceutical manufacturers with the means, including training tools and a starter kit, to implement quality risk management. The methodology relies on an interactive database that is accessible to industry.
This service, expected to be available soon, will be hosted and maintained on an independent platform that brings together industry, professional associations, and other pharmaceutical manufacturing partners. Drug manufacturers will be able to voluntarily integrate the system on a customer-supplier basis (see Figure 1).
Figure 1: Diagram of a sample operation in service. CAPA is corrective and preventive action. QRM is quality risk management. GMP is good manufacturing practice. (FIGURE 1 IS COURTESY OF THE AUTHORS)
The platform will make available the assistance necessary to implement the method, guarantee confidentiality, and use the information supplied exclusively for implementing the risk-management methodology.
The informal PIC/S working group has performed beta-tests on the proposed methodology. The methodology will, however, need to be placed under change-control management to achieve continuous improvement.
PIC/S will finalize and implement the example of methodology, possibly by the end of 2010.
Lionel Viornery is an inspector and head of the starting materials inspection unit at the French Health Products Safety Agency (Afssaps), 143/147, bd Anatole, Saint Denis cedex, 93285, France, firstname.lastname@example.org. Philippe Legoff is managing director of H&LG Consultants, Biolleyre 5, CH-1066 Epalinges, Switzerland, email@example.com