During the last meeting of FDA's Advisory Committee for Pharmaceutical
Science (ACPS) Manufacturing Subcommittee on July 20-21, 2004 Frederick
Razzaghi, Director of Technical Affairs, Consumer Healthcare Products
Association, gave a noteworthy presentation on the new ICH guideline Q9
"Risk Management".
The scope of this new guideline is determined by ICH to define how
principles of risk management can be more effectively applied and
consistently integrated into decisions, both by regulators and industry,
regarding the quality of pharmaceuticals across the product lifecycle,
including GMP compliance.
After a short overview about recent ICH activities concerning Q9,
Frederick Razzaghi explained in detail what Quality Risk Management
actually means and how it works. Above all the guiding principle should
be, that whatever you do during your process it should ultimately link
back to the potential risk to the patient.
Risk management itself can be divided into the following stages:
Initiate Process, Assess, Control, Communicate and Review. An important
statement Razzaghi makes on initiating risk management is that one should
define at this early step how assessment information and conclusions will
be used by the decision makers. Furthermore, he points out that one should
always ask "What are the impacts of current risk management decisions
on future options for risk management?". A questions that is often
neglected. At the end of his talk Razzaghi pays much attention to the
integration of Quality Risk Management into operations, into daily routine
work. He emphasizes that Risk Management is a tool that should be used
during development and regulatory scrutiny. Risk Management is also a
vital part of the Quality System from auditing to change management. It
has to be applied in facility systems management (e.g. hygiene,
qualification, computerized systems). It should be adopted to materials
management, production, laboratory controls, packaging and labeling as
well as regulatory authority activities. This list reflects ICH Q9's
lifecycle approach.
Frederick Razzaghi's presentation is of great benefit to those who want
to stay informed about recent regulatory developments on Risk Management
as well as to those who want to understand how Risk Management will
influence their daily work in the future.
An extra advantage of this presentation is the comprehensive list of
definitions to ensure that all have a common understanding of the terms
used in Risk Management.
The slides of Frederick Razzaghi's presentation can be downloaded here.