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Module 1GMP Workshop Kuala Lumpur 14-16 November. 2. CONTENT OF PRESENTATION. Basic Principles of Quality ManagementBasic Principles of Quality AssuranceBasic Requirements of Quality AssuranceBasic Principles of GMPBasic Requirements of GMPBasic Principles of Quality ControlBasic Requirements
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GMP Workshop Kuala Lumpur 14-16 November 2005 ASEAN GMP TRAINING MODULEQUALITY MANAGEMENT SYSTEM Complaint handling is defined in the ASEAN Cosmetic GMP. One necessary but not always pleasant aspect of quality management is dealing with complaints.
Complaint handling is defined in the ASEAN Cosmetic GMP. One necessary but not always pleasant aspect of quality management is dealing with complaints.
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GMP Workshop Kuala Lumpur 14-16 November 2 Content of presentation describes in 4 section :
Introduction
Objectives
Scope
Definition
Basic principle of product complaints
Product complaint principles
Role of manufacturer
Complaint handling principles
Complaint handling principle
Responsible person
Complaint handling procedure
Investigation
Investigation records
Remedial Action
Response
Decision from an investigation
Classification of defects & complaints
Trend review
Documentation
Reporting
Related hyperlink documents
ReferencesContent of presentation describes in 4 section :
Introduction
Objectives
Scope
Definition
Basic principle of product complaints
Product complaint principles
Role of manufacturer
Complaint handling principles
Complaint handling principle
Responsible person
Complaint handling procedure
Investigation
Investigation records
Remedial Action
Response
Decision from an investigation
Classification of defects & complaints
Trend review
Documentation
Reporting
Related hyperlink documents
References
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GMP Workshop Kuala Lumpur 14-16 November 5 Manufacturer should ensure the cosmetic products comply with the requirements of ASEAN Cosmetic Directives (ACD).
They should also comply with any other applicable regulations pertaining to your specific country.
The attainment of this quality objective should be led by the senior management and requires the participation and commitment by staff, by the company’s suppliers and distributors.
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GMP Workshop Kuala Lumpur 14-16 November 6 To achieve the reliable quality objective, there should be a comprehensive QA system incorporating GMP.
The QA system should be fully documented and its effectiveness should be monitored.
All parts of QA system should be adequately resourced with:
competent personnel
suitable and sufficient premises, equipment and facilities
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GMP Workshop Kuala Lumpur 14-16 November 7 QA covers all matters which individually or collectively influence the quality of a product.
It refers to a sum total of activities organized with an aim to ensure the products are of the required quality.
QA incorporates GMP and other factors that fall outside the scope of the GMP Guide.
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GMP Workshop Kuala Lumpur 14-16 November 8 Ensure that products are designed and developed based on sound scientific rationale and with GMP or GLP (Good Laboratory Practice) principles being taken into consideration.
Ensure that managerial responsibilities are clearly specified.
Ensure that production and control operations are clearly specified and GMP is adopted.
Organize supply and use of correct starting and packaging materials.
Ensure that finished products are correctly processed and checked before release.
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Ensure that products are released after review by authorised person.
Provide satisfactory arrangement to ensure products are stored, distributed & handled appropriately.
Put in place a mechanism for regular self inspection / internal quality audit.
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GMP Workshop Kuala Lumpur 14-16 November 10 Part of QA which ensures that products are consistently produced and controlled to the quality standards appropriate to their intended use.
Minimize risks :
cross contamination
mix up
Ensure products/materials are traceable to the original source.
Product testing is not reliable way to assure product quality. Should BUILD quality into the product!
Production and quality control functions should be independent of each other.
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GMP Workshop Kuala Lumpur 14-16 November 11 All manufacturing process are clearly defined and systematically reviewed.
All necessary facilities/resources for GMP should be provided :
adequate, qualified and well-trained personnel
suitable premises and sufficient space
suitable location
good personal hygiene and proper sanitation
suitable equipment and services
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GMP Workshop Kuala Lumpur 14-16 November 12 All necessary facilities/resources for GMP should be provided :
clearly defined manufacturing processes
using unambiguous language
good documentation system
appropriate storage and transport
systematic internal quality audit
proper product recall system
right handing of complaints
comprehensive corrective and preventive
action
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GMP Workshop Kuala Lumpur 14-16 November 13 QC is part of GMP.
QC is concerned with sampling, specification and testing.
Manufacturer should have a QC department.
QC should be headed by an appropriately qualified and experienced person.
QC should be independent from production and other departments.
Ensure that the necessary and relevant tests are actually carried out.
Ensure that no materials or products will be released for sale or supply, until their quality have been evaluated and judged to be satisfactory.
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GMP Workshop Kuala Lumpur 14-16 November 14 Items concerned :
Starting materials
Packaging materials
Bulk products
Intermediate and finished products
Environmental conditions
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GMP Workshop Kuala Lumpur 14-16 November 15 Adequate facilities, trained personnel and approved procedures should be available for sampling,
inspecting and testing and, where appropriate, environment monitoring.
Sampling by QC personnel & testing by approved
methods.
Approved test methods.
Maintenance of QC records & failure investigation records.
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Ingredients comply with regulatory specification (grade, composition, strength)
Review and evaluation of production documentation
Assessment of process deviations
Release of batches by authorised person
Sufficient reference samples of starting materials and finished products
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GMP Workshop Kuala Lumpur 14-16 November 17 Establish QC procedures
Manage reference standards
Ensure correct labeling
Stability testing (if applicable)
Complaint investigation
Environmental monitoring
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GMP Workshop Kuala Lumpur 14-16 November 18 Should include the following:
Production conditions
In process quality control activity
Manufacturing documentation
Compliance with finished product specification
Examination of the finished products
QC Access
QC personnel MUST have access to production area for sampling and investigation
Access to QC lab is strictly for QC personnel
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GMP Workshop Kuala Lumpur 14-16 November 19 QC should cover the following:
Sampling
Specification
Testing
Release procedures
Recalls and complaints
Decision making in all quality matters
Definition of product quality
Laboratory operations
Release authorisation
Investigation and reporting
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GMP Workshop Kuala Lumpur 14-16 November 32 This Quality Manual should state the company’s commitment to quality and describe the quality system of an organization .
Quality System refers to the appropriate infrastructure encompassing Procedures, Processes and Resources.
Included in the Quality Manual shall be a clearly defined and documented quality policy statement that states the company’s commitment to produce safe and quality products and its responsibility to its customers.
The company’s senior management shall demonstrate commitment to the implementation of the Company Quality Policy by signing off the policy.
All supervisory staff and key personnel shall understand and implement the policy.
The quality policy shall be communicated to all staff of the company and regularly reviewed.
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GMP Workshop Kuala Lumpur 14-16 November 35 Quality manual can be prepared according to ISO prescribed format if it does incorporate the GMP principles or it should contain the following features :
Title and Scope – which company sites and operations are covered?
Example:
This manual describes the quality arrangements for manufacturing process starting from receiving of starting materials to delivery of finished products which are manufactured at :
1 Sembawang Avenue
Singapore 123456
This manual describes the policies and summaries of the quality management system established.
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GMP Workshop Kuala Lumpur 14-16 November 36 Amendment/Revision History
A list of amendment identifiable by version number, date and a title or description of change
E.g.
Content Page
Distribution list
Quality Policy Statement
History /Background of the Company
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GMP Workshop Kuala Lumpur 14-16 November 37 Management Organisation
There should be a person named as management representative for ensuring the implementation of QM. This person should be appointed by senior management to represent the management authority and to monitor the system
Company organisational structure, authority, responsibilities and functions
Control of Manual
review and revision to ensure relevancy and accuracy
distribution
whose responsibilities for the control of manual
38. Module 1
GMP Workshop Kuala Lumpur 14-16 November 38 Quality Management System Contents
Describe how the quality management system works relating to
Personnel 8. Internal Audit
Premises 9. Storage
Equipment 10. Contract Manufacturing &
Sanitation & Hygiene Analysis
Production 11. Product Complaint
Quality Control 12. Product Recall
Documentation
It is important to draw attention to the specific use of formally written and established procedures.
Reference may be in the form of table appended to the manual
It should contain only the management policies which govern the application of procedures.
It is not normally sensible to include the technical procedures. They should be referred to specifically by title and reference number when appropriate.
39. Module 1
GMP Workshop Kuala Lumpur 14-16 November 39 Quick Checklist for a Quality Manual
Does it define the scope of the Quality Management System that it operates?
Is it a controlled document?
Is there an authorised management representative?
Are the organisation structure and control system described and documented?
40. Module 1
GMP Workshop Kuala Lumpur 14-16 November 40 Specify the company’s policies on :
Criteria of staff involved in the manufacturing activities
Assuring staff’s competency in their work
Assuring staff’s understanding of procedures, work instruction, GMP principles , etc
Assuring that there is no ambiguity of staff’s roles and responsibilities
Staff resources allocation
Authority of QC and Production
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GMP Workshop Kuala Lumpur 14-16 November 41
Specify the requirements of location, design , constructions and maintenance of manufacturing premises with respect to the following:
prevention of contamination from surrounding environment and pests
prevention of mix up of materials and products
facilities such as toilet, changing rooms, sampling areas and QC lab
defined areas for certain activities
wall, ceiling, drains , air intake and exhaust, lighting and ventilation, pipe work and light fitting
storage areas
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Describe the requirements of the design, installation and maintenance of the equipment and its support system such as ventilation system.
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Describe the control of manufacturing process with respect to the following :
Checking and verification of starting materials (r.m., p.m., and water)
Traceability of starting materials to the
product
Handling of rejected materials
Batch numbering system
Weighing and measurement
Production process of dry and wet products
Labeling and packaging
Finished product: Quarantine and Delivery
45. Module 1
GMP Workshop Kuala Lumpur 14-16 November 45 Describe how QC ensures products contain the correct materials of specified quality and quantity and are manufactured under proper conditions.
Describe the QC requirement on the following:
Sampling
Inspecting
Testing
Environmental monitoring programme
Review of batch documentation
Sample retention programme
Stability studies
Maintenance of material or product specification
Reprocessing
Returned products
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GMP Workshop Kuala Lumpur 14-16 November 46
Describe the documentation control system with respect to the following:
Documentation structure (e.g. Quality Manual, Quality Procedures, Instructions and Records)
Format requirement for different types of documents
Numbering and reference system
Handling of controlled and uncontrolled documents
Handling of obsolete versions
Preparation, approval, distribution of documents
Review and change control
Documentation controller
Storage of master documents
Retention period for records
List of controlled documents
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GMP Workshop Kuala Lumpur 14-16 November 47
Describe the policies related to Internal Audits
Audit team
Frequency of audit
Follow up actions
Who will be overall responsible for organising the internal audit
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GMP Workshop Kuala Lumpur 14-16 November 48
Specify the requirements concerning storage of materials/ products with respect to the following
Space, design, security and cleanliness
Storage of quarantine stocks
Storage of hazardous substances
Conditions of storage area (e.g. temperature & relative humidity)
Receiving of incoming materials
Stock control (e.g. FIFO principle, proper labeling on the container)
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Describe how the company ensures the contract giver or acceptor aware of the duties and responsibilities of each party so as to avoid misunderstanding.
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Describe the systems for recalling from the market of products known or suspected to be defective:
The designated person responsible for coordination
Classification of product recall
Provision of sufficient resources
Maintenance of Distribution records
Progress report and final report with reconciliation
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