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QUALITY RISK MANAGEMENT METHODS AND TOOLS

在文檔中 Q9(R1) Q R M (頁 24-37)

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The purpose of this annex is to provide a general overview of and references for some of the

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primary tools that might be used in quality risk management by industry and regulators. The

515

references are included as an aid to gain more knowledge and detail about the particular tool.

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This is not an exhaustive list. It is important to note that no one tool or set of tools is applicable

517

to every situation in which a quality risk management procedure is used.

518

It is neither always appropriate nor always necessary to use highly formal quality risk

519

management methods and tools. The use of less formal quality risk management methods and

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tools can also be considered acceptable. See Chapter 5 for guidance on what constitutes

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formality in quality risk management.

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I.1 Basic Risk Management Facilitation Methods 523

Some of the simple techniques that are commonly used to structure risk management by

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organizing data and facilitating decision-making are:

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• Flowcharts;

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• Check Sheets;

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• Process Mapping;

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• Cause and Effect Diagrams (also called an Ishikawa diagram or fish bone diagram).

529

I.2 Failure Mode Effects Analysis (FMEA) 530

FMEA (see IEC 60812) provides for an evaluation of potential failure modes for processes and

531

their likely effect on outcomes and/or product performance. Once failure modes are

532

established, risk reduction can be used to eliminate, contain, reduce or control the potential

533

failures. FMEA relies on product and process understanding. FMEA methodically breaks down

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the analysis of complex processes into manageable steps. It is a powerful tool for summarizing

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the important modes of failure, factors causing these failures and the likely effects of these

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failures.

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Potential Areas of Use(s)

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FMEA can be used to prioritize risks and monitor the effectiveness of risk control activities.

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FMEA can be applied to equipment and facilities and might be used to analyze a manufacturing

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operation and its effect on product or process. It identifies elements/operations within the

541

system that render it vulnerable. The output/ results of FMEA can be used as a basis for design

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or further analysis or to guide resource deployment.

543

I.3 Failure Mode, Effects and Criticality Analysis (FMECA) 544

FMEA might be extended to incorporate an investigation of the degree of severity of the

545

consequences, their respective probabilities of occurrence, and their detectability, thereby

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becoming a Failure Mode Effect and Criticality Analysis (FMECA; see IEC 60812). In order

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for such an analysis to be performed, the product or process specifications should be

548

established. FMECA can identify places where additional preventive actions might be

549

appropriate to minimize risks.

550

Potential Areas of Use(s)

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FMECA application in the pharmaceutical industry should mostly be utilized for failures and

552

risks associated with manufacturing processes; however, it is not limited to this application.

553

The output of an FMECA is a relative risk “score” for each failure mode, which is used to rank

554

the modes on a relative risk basis.

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I.4 Fault Tree Analysis (FTA) 556

The FTA tool (see IEC 61025) is an approach that assumes failure of the functionality of a

557

product or process. This tool evaluates system (or sub-system) failures one at a time but can

558

combine multiple causes of failure by identifying causal chains. The results are represented

559

pictorially in the form of a tree of fault modes. At each level in the tree, combinations of fault

560

modes are described with logical operators (AND, OR, etc.). FTA relies on the experts’ process

561

understanding to identify causal factors.

562

Potential Areas of Use(s)

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FTA can be used to establish the pathway to the root cause of the failure. FTA can be used to

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investigate complaints or deviations in order to fully understand their root cause and to ensure

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that intended improvements will fully resolve the issue and not lead to other issues (i.e. solve

566

one problem yet cause a different problem). Fault Tree Analysis is an effective tool for

567

evaluating how multiple factors affect a given issue. The output of an FTA includes a visual

568

representation of failure modes. It is useful both for risk assessment and in developing

569

monitoring programs.

570

I.5 Hazard Analysis and Critical Control Points (HACCP) 571

HACCP is a systematic, proactive, and preventive tool for assuring product quality, reliability,

572

and safety (see WHO Technical Report Series No 908, 2003 Annex 7). It is a structured

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approach that applies technical and scientific principles to analyze, evaluate, prevent, and

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control the risk or adverse consequence(s) of hazard(s) due to the design, development,

575

production, and use of products.

576

HACCP consists of the following seven steps:

577

(1) conduct a hazard analysis and identify preventive measures for each step of the process;

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(2) determine the critical control points;

579

(3) establish critical limits;

580

(4) establish a system to monitor the critical control points;

581

(5) establish the corrective action to be taken when monitoring indicates that the critical

582

control points are not in a state of control;

583

(6) establish system to verify that the HACCP system is working effectively;

584

(7) establish a record-keeping system.

585

Potential Areas of Use(s)

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HACCP might be used to identify and manage risks associated with physical, chemical and

587

biological hazards (including microbiological contamination). HACCP is most useful when

588

product and process understanding is sufficiently comprehensive to support identification of

589

critical control points. The output of a HACCP analysis is risk management information that

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facilitates monitoring of critical points not only in the manufacturing process but also in other

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life cycle phases.

592 593

I.6 Hazard Operability Analysis (HAZOP) 594

HAZOP (see IEC 61882) is based on a theory that assumes that risk events are caused by

595

deviations from the design or operating intentions. It is a systematic brainstorming technique

596

for identifying hazards using so-called “guide-words”. “Guide-words” (e.g., No, More, Other

597

Than, Part of, etc.) are applied to relevant parameters (e.g., contamination, temperature) to help

598

identify potential deviations from normal use or design intentions. It often uses a team of people

599

with expertise covering the design of the process or product and its application.

600

Potential Areas of Use(s)

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HAZOP can be applied to manufacturing processes, including outsourced production and

602

formulation as well as the upstream suppliers, equipment and facilities for drug substances and

603

drug (medicinal) products. It has also been used primarily in the pharmaceutical industry for

604

evaluating process safety hazards. As is the case with HACCP, the output of a HAZOP analysis

605

is a list of critical operations for risk management. This facilitates regular monitoring of critical

606

points in the manufacturing process.

607

I.7 Preliminary Hazard Analysis (PHA) 608

PHA is a tool of analysis based on applying prior experience or knowledge of a hazard or

609

failure to identify future hazards, hazardous situations and events that might cause harm, as

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well as to estimate their probability of occurrence for a given activity, facility, product or

611

system. The tool consists of: 1) the identification of the possibilities that the risk event happens,

612

2) the qualitative evaluation of the extent of possible injury or damage to health that could

613

result and 3) a relative ranking of the hazard using a combination of severity and likelihood of

614

occurrence, and 4) the identification of possible remedial measures.

615

Potential Areas of Use(s)

616

PHA might be useful when analyzing existing systems or prioritizing hazards where

617

circumstances prevent a more extensive technique from being used. It can be used for product,

618

process and facility design as well as to evaluate the types of hazards for the general product

619

type, then the product class, and finally the specific product. PHA is most commonly used early

620

in the development of a project when there is little information on design details or operating

621

procedures; thus, it will often be a precursor to further studies. Typically, hazards identified in

622

the PHA are further assessed with other risk management tools such as those in this section.

623

I.8 Risk Ranking and Filtering 624

Risk ranking and filtering is a tool for comparing and ranking risks. Risk ranking of complex

625

systems typically requires evaluation of multiple diverse quantitative and qualitative factors

626

for each risk. The tool involves breaking down a basic risk question into as many components

627

as needed to capture factors involved in the risk. These factors are combined into a single

628

relative risk score that can then be used for ranking risks. “Filters,” in the form of weighting

629

factors or cut-offs for risk scores, can be used to scale or fit the risk ranking to management or

630

policy objectives.

631

Potential Areas of Use(s)

632

Risk ranking and filtering can be used to prioritize manufacturing sites for inspection/audit by

633

regulators or industry. Risk ranking methods are particularly helpful in situations in which the

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portfolio of risks and the underlying consequences to be managed are diverse and difficult to

635

compare using a single tool. Risk ranking is useful when management needs to evaluate both

636

quantitatively-assessed and qualitatively-assessed risks within the same organizational

637

framework.

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I.9 Supporting Statistical Tools 639

Statistical tools can support and facilitate quality risk management. They can enable effective

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data assessment, aid in determining the significance of the data set(s), and facilitate more

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reliable decision making. A listing of some of the principal statistical tools commonly used in

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the pharmaceutical industry is provided:

643

• Control Charts, for example:

644

- Acceptance Control Charts (see ISO 7966);

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- Control Charts with Arithmetic Average and Warning Limits (see ISO 7873);

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- Cumulative Sum Charts (see ISO 7871);

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- Shewhart Control Charts (see ISO 8258);

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- Weighted Moving Average.

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• Design of Experiments (DOE);

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• Histograms;

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• Pareto Charts;

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• Process Capability Analysis.

653

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ANNEX II: QUALITY RISK MANAGEMENT AS PART OF INTEGRATED QUALITY

655

MANAGEMENT

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This Annex is intended to identify potential uses of quality risk management principles and

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tools by industry and regulators. However, the selection of particular risk management tools is

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completely dependent upon specific facts and circumstances.

659

These examples are provided for illustrative purposes and only suggest potential uses of quality

660

risk management. This Annex is not intended to create any new expectations beyond the current

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regulatory requirements.

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II.1 Quality Risk Management as Part of Integrated Quality Management 663

Documentation

664

To review current interpretations and application of regulatory expectations;

665

To determine the desirability of and/or develop the content for SOPs, guidelines, etc.

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Training and education

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To determine the appropriateness of initial and/or ongoing training sessions based on

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education, experience and working habits of staff, as well as on a periodic assessment of

669

previous training (e.g., its effectiveness);

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To identify the training, experience, qualifications and physical abilities that allow personnel

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to perform an operation reliably and with no adverse impact on the quality of the product.

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Quality defects

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To provide the basis for identifying, evaluating, and communicating the potential quality

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impact of a suspected quality defect, complaint, trend, deviation, investigation, out of

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To facilitate risk communications and determine appropriate action to address significant

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product defects, in conjunction with regulatory authorities (e.g., recall).

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Auditing/Inspection

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To define the frequency and scope of audits, both internal and external, taking into account

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factors such as:

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• Existing legal requirements;

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• Overall compliance status and history of the company or facility;

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• Robustness of a company’s quality risk management activities;

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• Complexity of the site;

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• Complexity of the manufacturing process;

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• Complexity of the product and its therapeutic significance;

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• Number and significance of quality defects (e.g., recall);

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• Results of previous audits/inspections;

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• Major changes of building, equipment, processes, key personnel;

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• Experience with manufacturing of a product (e.g., frequency, volume, number of

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batches);

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• Test results of official control laboratories.

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Periodic review

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To select, evaluate and interpret trend results of data within the product quality review;

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To interpret monitoring data (e.g., to support an assessment of the appropriateness of

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revalidation or changes in sampling).

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Change management / change control

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To manage changes based on knowledge and information accumulated in pharmaceutical

699

development and during manufacturing;

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To evaluate the impact of the changes on the availability of the final product;

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To evaluate the impact on product quality of changes to the facility, equipment, material,

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manufacturing process or technical transfers;

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To determine appropriate actions preceding the implementation of a change, e.g., additional

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testing, (re)qualification, (re)validation or communication with regulators.

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Continual improvement

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To facilitate continual improvement in processes throughout the product lifecycle.

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II.2 Quality Risk Management as Part of Regulatory Operations 708

Inspection and assessment activities

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To assist with resource allocation including, for example, inspection planning and frequency,

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and inspection and assessment intensity (see "Auditing" Section in Annex II.1);

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To evaluate the significance of, for example, quality defects, potential recalls and inspectional

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findings;

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To determine the appropriateness and type of post-inspection regulatory follow-up;

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To evaluate information submitted by industry including pharmaceutical development

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information;

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To evaluate impact of proposed variations or changes;

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To identify risks which should be communicated between inspectors and assessors to facilitate

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better understanding of how risks can be or are controlled (e.g., parametric release, Process

719

Analytical Technology (PAT)).

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II.3 Quality Risk Management as Part of development 721

To design a quality product and its manufacturing process to consistently deliver the intended

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performance of the product (see ICH Q8);

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To enhance knowledge of product performance over a wide range of material attributes (e.g.,

724

particle size distribution, moisture content, flow properties), processing options and process

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parameters;

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To assess the critical attributes of raw materials, solvents, Active Pharmaceutical Ingredient

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(API) starting materials, APIs, excipients, or packaging materials;

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To establish appropriate specifications, identify critical process parameters and establish

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manufacturing controls (e.g., using information from pharmaceutical development studies

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regarding the clinical significance of quality attributes and the ability to control them during

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processing);

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To decrease variability of quality attributes:

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• reduce product and material defects;

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• reduce manufacturing defects.

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To assess the need for additional studies (e.g., bioequivalence, stability) relating to scale up

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and technology transfer;

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To make use of the “design space” concept (see ICH Q8).

738

II.4 Quality Risk Management for Facilities, Equipment and Utilities 739

Design of facility / equipment

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To determine appropriate zones when designing buildings and facilities, e.g.,

741

• flow of material and personnel;

742

• minimize contamination;

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• pest control measures;

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• prevention of mix-ups;

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• open versus closed equipment;

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• clean rooms versus isolator technologies;

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• dedicated or segregated facilities / equipment.

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To determine appropriate product contact materials for equipment and containers (e.g.,

749

selection of stainless steel grade, gaskets, lubricants);

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To determine appropriate utilities (e.g., steam, gases, power source, compressed air, heating,

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ventilation and air conditioning (HVAC), water);

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To determine appropriate preventive maintenance for associated equipment (e.g., inventory of

753

necessary spare parts).

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Hygiene aspects in facilities

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To protect the product from environmental hazards, including chemical, microbiological, and

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physical hazards (e.g., determining appropriate clothing and gowning, hygiene concerns);

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To protect the environment (e.g., personnel, potential for cross-contamination) from hazards

758

related to the product being manufactured.

759

Qualification of facility/equipment/utilities

760

To determine the scope and extent of qualification of facilities, buildings, and production

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equipment and/or laboratory instruments (including proper calibration methods).

762

Cleaning of equipment and environmental control

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To differentiate efforts and decisions based on the intended use (e.g., multi- versus

single-764

purpose, batch versus continuous production);

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To determine acceptable (specified) cleaning validation limits.

766

Calibration/preventive maintenance

767

To set appropriate calibration and maintenance schedules.

768

Computer systems and computer controlled equipment

769

To select the design of computer hardware and software (e.g., modular, structured, fault

770

tolerance);

771

To determine the extent of validation, e.g.,

772

• selection of the requirements and design;

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• code review;

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• the extent of testing and test methods;

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• reliability of electronic records and signatures.

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II.5 Quality Risk Management as Part of Materials Management 778

Assessment and evaluation of suppliers and contract manufacturers

779

To provide a comprehensive evaluation of suppliers and contract manufacturers (e.g., auditing,

780

supplier quality agreements).

781

Starting material

782

To assess differences and possible quality risks associated with variability in starting materials

783

(e.g., age, route of synthesis).

784

Use of materials

785

To determine whether it is appropriate to use material under quarantine (e.g., for further internal

786

processing);

787

To determine appropriateness of reprocessing, reworking, use of returned goods.

788

Storage, logistics and distribution conditions

789

To assess the adequacy of arrangements to ensure maintenance of appropriate storage and

790

transport conditions (e.g., temperature, humidity, container design);

791

To determine the effect on product quality of discrepancies in storage or transport conditions

792

(e.g., cold chain management) in conjunction with other ICH guidelines;

793

To maintain infrastructure (e.g., capacity to ensure proper shipping conditions, interim storage,

794

handling of hazardous materials and controlled substances, customs clearance);

795

To provide information for ensuring the availability of pharmaceuticals (e.g., ranking risks to

796

the supply chain).

797

II.6 Quality Risk Management as Part of Production 798

Validation

799

To identify the scope and extent of verification, qualification and validation activities (e.g.,

800

analytical methods, processes, equipment and cleaning methods;

801

To determine the extent for follow-up activities (e.g., sampling, monitoring and re-validation);

802

To distinguish between critical and non-critical process steps to facilitate design of a validation

803

study.

804

In-process sampling & testing

805

To evaluate the frequency and extent of in-process control testing (e.g., to justify reduced

806

testing under conditions of proven control);

807

To evaluate and justify the use of process analytical technologies (PAT) in conjunction with

808

parametric and real time release.

809

Production planning

810

To determine appropriate production planning (e.g., dedicated, campaign and concurrent

811

production process sequences).

812

II.7 Quality Risk Management as Part of Laboratory Control and Stability Studies 813

Out of specification results

814

To identify potential root causes and corrective actions during the investigation of out of

815

specification results.

816

Retest period / expiration date

817

To evaluate adequacy of storage and testing of intermediates, excipients and starting materials.

818

II.8 Quality Risk Management as Part of Packaging and Labelling 819

Design of packages

820

To design the secondary package for the protection of primary packaged product (e.g., to ensure

821

Selection of container closure system

823

To determine the critical parameters of the container closure system.

824

Label controls

825

To design label control procedures based on the potential for mix-ups involving different

826

product labels, including different versions of the same label.

827

II.9 Quality Risk Management as Part of Supply Chain Control 828

With regard to product availability risks related to quality/manufacturing issues, lifecycle

829

oversight of the supply chain includes maintaining current knowledge of quality/manufacturing

830

hazards and prioritizing efforts to manage such risks. Understanding hazards

831

to quality/manufacturing is critical to maintaining supply predictability. When risks are well

832

understood and minimized, a higher confidence in product availability can be attained.

833

Manufacturing Process Variation and State of Control

834

To decrease variability in the manufacturing process (e.g., process drift, non-uniformity) and

835

associated capability gaps that can result in unpredictable outputs, adversely impact quality and

836

consequently timeliness, yield and product availability;

837

To design monitoring systems that are capable of detecting departures from a state of control

838

and deficiencies in manufacturing processes, so they can be appropriately investigated to

839

determine root causes and any required risk mitigations.

840

Manufacturing Facilities

841

To ensure that facility infrastructure and equipment are suitable and well-designed for

842

manufacturing and packaging;

843

To establish equipment and facility maintenance programmes that assure reliable facility and

844

equipment performance;

845

To ensure that the operational design of equipment is not vulnerable to human error;

846

To obtain efficiency gains (e.g. speed, throughput, supply timeliness, etc.) from investing in

847

quality through the utilization of digitalization, automation, isolation technology, and other

848

innovations.

849

Supplier Oversight and Relationships

850

To enhance review and monitoring activities (see Section 2.7 of ICH Q10) when substantial

851

variability is identified in the quality and safety of supplied materials or in the services

852

provided.

853

To manage external product availability risks relating to quality/manufacturing, (e.g. from raw

854

material suppliers, contracted organizations, service providers, etc.)

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在文檔中 Q9(R1) Q R M (頁 24-37)

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