RESOURCES-THE QUALITY SYSTEMS MODEL
Appropriate allocation of resources is key to creating a robust quality system and complying with the CGMP regulations. This section discusses the role of resources in developing, implementing, and managing a robust quality system that complies with CGMP regulations.
1. General Arrangements
Under a robust quality system, sufficient resources should be allocated for quality system and
operational activities. Under the model, senior management, or a designee, should be
responsible for providing adequate resources for the following:
- To supply and maintain the appropriate facilities and equipment to consistently manufacture a quality product.
- To acquire and receive materials that are suitable for their intended purpose
- For processing the materials to produce the finished drug product
- For laboratory analysis of the finished drug product, including collection, storage, and
examination of in-process, stability, and reserve samples.
2. Personnel Development
Under a quality system, senior management should support a problem-solving and communicative organizational culture. Managers should encourage communication by creating an environment that values employee suggestions and acts on suggestions for improvement.
Management should also develop cross-functional groups to share ideas to improve procedures and processes.
In a quality system, personnel should be qualified to do the operations that are assigned to them in accordance with the nature of, and potential risk of, their operational activities. Under a quality system, managers should define appropriate qualifications for each position to help ensure that individuals are assigned appropriate responsibilities. Personnel should also understand the effect of their activities on the product and the customer. Although QU personnel should not take on the responsibilities of other units of the organization, this personnel should
be selected based on their scientific and technical understanding, product knowledge, process knowledge and/or risk assessment abilities to appropriately execute certain quality functions (this quality systems feature is also found in the CGMP regulations, which identify specific qualifications, such as education, training, and experience or any combination thereof (see §211.25(a) and (b)).
Under a quality system, continued training is critical to ensure that the employees remain proficient in their operational functions and in their understanding of CGMP regulations.
Typical quality systems training should address the policies, processes, procedures, and written instructions related to operational activities, the product/service, the quality system, and the desired work culture (e.g., team building, communication, change, and behavior). Under a quality system (and the CGMP regulations), training should focus on both the employees’ specific job functions and the related CGMP regulatory requirements.
Under a quality system, managers are expected to establish training programs that include the following:
- Evaluation of training needs
- Provision of training to satisfy these needs
- Evaluation of effectiveness of training
- Documentation of training and/or re-training
When operating in a robust quality system environment, it is important that managers verify that skills gained from training are implemented in day-to-day performance.
3. Facilities and Equipment
Under a quality system, the technical experts (e.g., engineers, development scientists), who have an understanding of pharmaceutical science, risk factors, and manufacturing processes related to the product, are responsible for defining specific facility and equipment requirements.
Under the CGMP regulations, the quality unit ( QU) has the responsibility of reviewing and approving all initial design criteria and procedures pertaining to facilities and equipment and any subsequent changes (§ 211.22(c)).
Under the CGMP regulations, equipment must be qualified, calibrated, cleaned, and maintained to prevent contamination and mix-ups (§§ 211.63, 211.67, 211.68). Note that the CGMP regulations require a higher standard for calibration and maintenance than most nonpharmaceutical quality system models. The CGMP regulations place as much emphasis on process equipment as on testing equipment (§§ 211.160, 211.63, 211.67, and 211.68) while most
quality systems focus only on testing equipment.
4. Control Outsourced Operations
Outsourcing involves hiring a second party under a contract to perform the operational processes that are part of a manufacturer’s inherent responsibilities. For example, a manufacturer may hire another firm to package and label or perform CGMP regulatory training. Quality systems call for contracts (quality agreements) that clearly describe the materials or service, quality specification responsibilities, and communication mechanisms.
Under a quality system, the manufacturer should ensure that a contract firm is qualified before signing a contract with that firm. The contract firm’s personnel should be adequately trained and monitored for performance according to their quality system, and the contract firm’s and contracting manufacturer’s quality standards should not conflict. It is critical in a quality system to ensure that the management of the contractor is familiar with the specific requirements of the contract.
However, under the CGMP requirements, the manufacturer’s QU is responsible for approving or rejecting products or services provided under a contract (§ 211.22(a)).
As the following table illustrates, the CGMP regulations are consistent with the elements of a quality system in many areas in this section. However, manufacturers should always refer to the specific regulations to ensure that they are complying with all regulations.
CGMPS AND THE CONCEPTS OF MODERN QUALITY SYSTEMS