EU regulations require all pharmaceutical manufacturers to comply with EU Good Manufacturing Practices (GMPs) if they want to supply products to the EU.
- Manufacturers and importers must be authorised and registered by a competent authority from a member state.
- Manufacturers and importers are regularly inspected by an EU competent authority or other approved authority to check compliance with the EU GMPs. This applies wherever the manufacturer is located.
- The frequency of inspection is based on a risk assessment and in addition the local national competent authority must supply written confirmation that each batch of product conformed to GMPs.
- Where products are imported by a separate company the importer is responsible for ensuring compliance with GMP.
The EU legislation governing pharmaceutical products is compiled in the publication “The rules governing medicinal products in the European Union”.
In addition, the European Directorate for the Quality of Medicines and Healthcare (EDQM) of the Council of Europe (separate from the EU and EC), which is responsible for the European Pharmacopoeia, can also inspect manufacturers and issue Certificates of Suitability that can replace most of the data in the EU Marketing Authorisation of medicines (Luigetta R, 2015).
In the US, the regulatory standard for human pharmaceutical products is the Current Good Manufacturing Practice regulations, which are enforced by the FDA.
Internation Society for Pharmaceutical Engineering (ISPE) has compiled links to GMP regulations and resources for individual countries: Australia, Canada, China, EU, India, Japan, US: ispe.org/gmp-resources/regulations.
Sanitation and hygiene GMPs
Good Manufacturing Practices form part of a pharmaceutical quality system. It aims to minimise the risks in manufacture to ensure safety, quality and efficacy.
- A manufacturer has responsibility to ensure the pharmaceutical products are fit for use, comply with marketing authorisation requirements and have adequate safety, quality and efficacy.
- Senior management has the responsibility to ensure that the pharmaceutical quality system is adequately resourced, roles, responsibilities and authorities are clearly defined and communicated.
- Pharmaceutical manufacture requires high levels of sanitation and hygiene at every point of the process, covering personnel, premises, equipment, materials, containers, and cleaning and disinfection products.
- It also requires elimination of potential sources of contamination, both for hygiene purposes and for medical effectiveness, which could be affected by, for example, dust from other product ingredients or cleaning compounds.
The basic sanitation and hygiene GMPs below are derived from WHO guidelines (WHO, 2011):
There should be sufficient numbers of qualified personnel who should be aware of the principles of GMP applicable to their role, including hygiene practices.
- Health checks: personnel should undergo health checks before and during employment.
- Hygiene practices: all personnel involved in the manufacturing process should practice a high level of personal hygiene.
- Illness: staff having an illness or open wounds that could affect product quality must not handle starting materials, packaging, in-process materials or medicines, until they have recovered and are no longer a risk. Staff and contractors who may be suffering from a food-borne illness (symptoms include diarrhoea, vomiting, hepatitis) must inform the customer site contact and determine whether they may enter the pharmaceutical company premises.
- Handling goods: there should be no direct contact between hands and starting materials, primary packaging materials, and intermediate or bulk products.
- Clothing: persons in the production areas should wear clean body coverings as appropriate, including production staff, contractors, employees, visitors, managers and inspectors.
- Personal habits: eating, drinking, chewing, smoking should not be allowed in the production, laboratory and storage areas. Food, drink, smoking products and personal medicines should not be allowed in these areas also.
- Location: premises should be located in an environment that minimises the risk of contamination of materials and products.
- Design and layout: the design and layout of the premises must facilitate good sanitation and allow effective cleaning and maintenance to prevent cross-contamination and build-up of dirt. As well as being appropriate for the activities for which the premises are used, the design and construction of pharmaceutical premises should not permit the entry of pests and not provide harbourage for pests.
- Pest control: there should be pest control procedures that encompass Integrated Pest Management (IPM) to reduce or eliminate pests.
- Cross-contamination: measures should be taken to prevent cross-contamination from dust generated during manufacturing operations from handling of ingredients.
- Cleaning: premises should be cleaned and disinfected according to written procedures and records kept.
- Services: lighting, temperature, humidity, ventilation and electrical supply should not adversely affect pharmaceutical products or the functioning of equipment.
- Staff facilities: facilities for changing, washing, toilets, eating and rest should be separate from production and storage areas. Facilities should be appropriate for the number of users.
- Storage areas: these should be designed to ensure suitable conditions: dry, clean, well lit, and maintained within suitable temperature limits.
- Delivery and dispatch areas: these should be designed to protect products from the weather and be designed and equipped to allow cleaning of delivery containers.
- The layout of production areas: premises should be designed to allow production to take place in a logical order and with required cleanliness levels.
- Surfaces: interior surfaces of walls, floors, ceilings should be smooth, free of cracks and loose materials, and allow effective cleaning and disinfection.
- Fittings: pipework, light fittings, ventilation fittings should be designed for ease of cleaning and maintenance.
- Drains: drains should be of sufficient capacity and designed to prevent back flow
- Ventilation: production areas should have suitable ventilation to prevent contamination from external and internal sources, and control temperature and humidity as appropriate.
- Layout and design: the layout and design of equipment should allow effective cleaning and maintenance and prevent cross-contamination and build-up of dirt or dust. Layout and design should not permit pest harbourage.
- Cleaning: equipment should be cleaned using validated procedures, according to a suitable schedule and records kept of the procedures, times and results of tests.
- Equipment for cleaning: equipment for washing, cleaning and drying should be suitable for use and not contaminate products.
- Cleaning: materials used for cleaning should be of the appropriate grade for use with pharmaceutical equipment and should not come into contact with products.
- Pest control: pest control materials, including rodenticides, insecticides and fumigation gases, should not contaminate equipment, starting materials, packaging materials, materials in process or finished products.
- Water: water used in the manufacturing process should be of suitable quality.
Waste should be removed from production areas and properly stored in suitable containers in designated areas and disposed of in a timely manner.
Standard operating procedures and records
Standard operating procedures, with appropriate records should include:
- maintenance, cleaning and sanitization, including for each piece of equipment;
- relevant personnel matters including qualifications, training, clothing and hygiene;
- pest control: the pest control contractor should have a Standard Operating Procedure (SOP) that complies with HACCP and is designed by the pest manager in conjunction with the pharmaceutical business. The program should support the GMP for the pharmaceutical business and include all legislative requirements and ensures Industry best practices.
Good production practices
Pharmaceutical products need particular care to prevent contamination and cross-contamination from materials and other products such as living microorganisms, hormones, toxic substances, and other active substances.
- Cross-contamination: this can occur from the release of dust, gases, particles, vapours, sprays or organisms from materials and products in production processes. Appropriate measures to prevent this include:
- self-contained production areas;
- airlocks, pressure differential, air supply and extraction systems, as appropriate for the required cleanliness levels;
- wearing protective clothing;
- using effective cleaning and decontamination procedures;
- Contamination: any foreign object or material found in the finished product could also introduce disease or cause poisoning of consumers. Contamination can be physical, biological and chemical e.g. insects, rodents, rodent droppings, pathogens such as Salmonella, Listeria, E.coli. Contamination can occur from:
- residues on equipment;
- insects and other pests;
- operators’ clothing, skin, jewellery etc. Staff and contractors must have a documented clothing and jewellery policy.
- particles from the building structure and fittings;
- pipework supplying water, including distilled or deionised water; these should be free of defects and cleaned appropriately;
- containers in the production line should be cleaned before filling and any physical contaminants removed.