Risk managementprinciples are effectively utilized in many areas of business and government including finance, insurance, occupational safety, public health, pharmacovigilance, and by agencies regulating these industries.
Quality risk management is used in the pharmaceutical industries and it is becoming evident that quality risk management is a valuable component of an effective quality system.
Advantages of Quality risk Management:
An effective quality risk management approach can further ensure the high quality of the drug (medicinal) product to the patient by providing a proactive means to identify and control potential quality issues during development and manufacturing.
The use of quality risk management can improve the decision making if a quality problem arises.
Effective quality risk management can facilitate better and more informed decisions, can provide regulators with greater assurance of a company’s ability to deal with potential risks and can beneficially affect the extent and level of direct regulatory oversight.
This Appendix is intended to identify potential uses of quality risk management principles and tools by industry and regulators. However, the selection of particular risk management tools is completely dependent upon specific facts and circumstances. These examples are provided for illustrative purposes and only suggest potential uses of quality risk management (but not limited to).
1. Quality Risk Management as Part of Integrated Quality Management
To review current interpretations and application of regulatory expectations
To determine the desirability of and/or develop the content for SOPs, guidelines, etc.
Training and education
To determine the appropriateness of initial and/or ongoing training sessions based on education, experience and working habits of staff, as well as on a periodic assessment of previous training (e.g., its effectiveness)
To identify the training, experience, qualifications and physical abilities that allow personnel to perform an operation reliably and with no adverse impact on the quality of the product
To provide the basis for identifying, evaluating, and communicating the potential quality impact of a suspected quality defect, complaint, trend, deviation, investigation, out of specification result, etc.
To facilitate risk communications and determine appropriate action to address significant product defects, in conjunction with regulatory authorities (e.g., recall)
To define the frequency and scope of audits, both internal and external, taking into account factors such as:
• Existing legal requirements
• Overall compliance status and history of the company or facility
• Robustness of a company’s quality risk management activities
• Complexity of the site
• Complexity of the manufacturing process
• Complexity of the product and its therapeutic significance
• Number and significance of quality defects (e.g. recall)
• Results of previous audits/inspections
- Major changes of building, equipment, processes, key personnel
- Experience with manufacturing of a product (e.g. frequency, volume, number of batches)
- Test results of official control laboratories
To select, evaluate and interpret trend results of data within the product quality review
To interpret monitoring data (e.g., to support an assessment of the appropriateness of re validation or changes in sampling)
Change management / change control
To manage changes based on knowledge and information accumulated in pharmaceutical development and during manufacturing
To evaluate the impact of the changes on the availability of the final product
To evaluate the impact on product quality of changes to the facility, equipment, material, manufacturing process or technical transfers
To determine appropriate actions preceding the implementation of a change, e.g., additional testing, (re)qualification, (re)validation or communication with regulators
To facilitate continual improvement in processes throughout the product lifecycle
2. Quality Risk Management as Part of Regulatory Operations
Inspection and assessment activities
To assist with resource allocation including, for example, inspection planning and frequency, and inspection and assessment intensity.
To evaluate the significance of, for example, quality defects, potential recalls and inspectional findings
To determine the appropriateness and type of post-inspection regulatory follow-up
To evaluate information submitted by industry including pharmaceutical development information
To evaluate impact of proposed variations or changes
To identify risks which should be communicated between inspectors and assessors to facilitate better understanding of how risks can be or are controlled (e.g. parametric release, Process Analytical Technology (PAT)).
3. Quality Risk Management as Part of Development
To design a quality product and its manufacturing process to consistently deliver the intended performance of the product (see ICH Q8)
To enhance knowledge of product performance over a wide range of material attributes (e.g. particle size distribution, moisture content, flow properties), processing options and process parameters
To assess the critical attributes of raw materials, solvents, Active Pharmaceutical Ingredient (API) starting materials, APIs, excipients, or packaging materials
To establish appropriate specifications, identify critical process parameters and establish manufacturing controls (e.g., using information from pharmaceutical development studies regarding the clinical significance of quality attributes and the ability to control them during processing)
To decrease variability of quality attributes:
• reduce product and material defects
• reduce manufacturing defects
To assess the need for additional studies (e.g., bioequivalence, stability) relating to scale up and technology transfer
To make use of the “design space” concept (see ICH Q8).
4. Quality Risk Management for Facilities, Equipment and Utilities
Design of facility / equipment
To determine appropriate zones when designing buildings and facilities, e.g.,
• flow of material and personnel
• minimize contamination
• pest control measures
• prevention of mix-ups
• open versus closed equipment
• clean rooms versus isolator technologies
• dedicated or segregated facilities / equipment
To determine appropriate product contact materials for equipment and containers (e.g., selection of stainless steel grade, gaskets, lubricants)
To determine appropriate utilities (e.g., steam, gases, power source, compressed air, heating, ventilation and air conditioning (HVAC), water).
To determine appropriate preventive maintenance for associated equipment (e.g., inventory of necessary spare parts).
Hygiene aspects in facilities
To protect the product from environmental hazards, including chemical, microbiological, and physical hazards (e.g., determining appropriate clothing and gowning, hygiene concerns)
To protect the environment (e.g., personnel, potential for cross-contamination) from hazards related to the product being manufactured
Qualification of facility/equipment/utilities
To determine the scope and extent of qualification of facilities, buildings, and production equipment and/or laboratory instruments (including proper calibration methods)
Cleaning of equipment and environmental control
To differentiate efforts and decisions based on the intended use (e.g. multi-versus single-purpose, batch versus continuous production)
To determine acceptable (specified) cleaning validation limits
To set appropriate calibration and maintenance schedules
Computer systems and computer controlled equipment
To select the design of computer hardware and software (e.g., modular, structured, fault tolerance)
To determine the extent of validation, e.g.:
• identification of critical performance parameters
• selection of the requirements and design
• code review
• the extent of testing and test methods
• reliability of electronic records and signatures
5. Quality Risk Management as Part of Materials Management
Assessment and evaluation of suppliers and contract manufacturers
To provide a comprehensive evaluation of suppliers and contract manufacturers (e.g., auditing, supplier quality agreements)
To assess differences and possible quality risks associated with variability in starting materials (e.g., age, route of synthesis).
Use of materials
To determine whether it is appropriate to use material under quarantine (e.g., for further internal processing)
To determine appropriateness of reprocessing, reworking, use of returned goods
Storage, logistics and distribution conditions
To assess the adequacy of arrangements to ensure maintenance of appropriate storage and transport conditions (e.g., temperature, humidity, container design)
To determine the effect on product quality of discrepancies in storage or transport conditions (e.g. cold chain management) in conjunction with other ICH guidelines
To maintain infrastructure (e.g. capacity to ensure proper shipping conditions, interim storage, handling of hazardous materials and controlled substances, customs clearance)
To provide information for ensuring the availability of pharmaceuticals (e.g. ranking risks to the supply chain).
6. Quality Risk Management as Part of Production
To identify the scope and extent of verification, qualification and validation activities (e.g., analytical methods, processes, equipment and cleaning methods
To determine the extent for follow-up activities (e.g., sampling, monitoring and re-validation)
To distinguish between critical and non-critical process steps to facilitate design of a validation study
In-process sampling & testing
To evaluate the frequency and extent of in-process control testing (e.g., to justify reduced testing under conditions of proven control)
To evaluate and justify the use of process analytical technologies (PAT) in conjunction with parametric and real time release
To determine appropriate production planning (e.g. dedicated, campaign and concurrent production process sequences).
7. Quality Risk Management as Part of Laboratory Control and Stability Studies
Out of specification results
To identify potential root causes and corrective actions during the investigation of out of specification results
Retest period / expiration date
To evaluate adequacy of storage and testing of intermediates, excipients and starting materials.
8. Quality Risk Management as Part of Packaging and Labelling
Design of packages
To design the secondary package for the protection of primary packaged product (e.g., to ensure product authenticity, label legibility)
Selection of container closure system
To determine the critical parameters of the container closure system
To design label control procedures based on the potential for mix-ups involving different product labels, including different versions of the same label