The systematic analysis of the GMP deficiencies recorded during an inspection reflects, on the one hand, what FDA inspectors focus on and, on the other hand, provides clues for preparing for an upcoming inspection by the FDA. The sometimes quite detailed descriptions of the GMP violations are facilitated by topic-related statistics, which are carried out annually by Concept Heidelberg in the context of the respective completed fiscal year.
In the fiscal year 2022 (Oct. 2021 - Sept. 2022), a total of 42 Warning Letters were sent to medicinal product manufacturers, each explicitly describing the GMP deficiencies in connection with the paragraphs of 21 CFR 211. After analysing these "Drugs" Warning Letters, the "hit parade" of the 10 most frequently cited GMP sins looks as follows:
First on this list is paragraph 211.22, which sets out the requirements for the quality assurance unit in terms of its responsibilities. The GMP violations described in the 23 Warning Letters can be grouped as follows:
QA review of batch documentation and batch release
QA releases batches that have been tested using non-validated methods.
QA releases batches prior to review of manufacturing documentation.
Responsibilities of the Quality Unit towards contract manufacturers and contract laboratories
There are no quality agreements.
There is no release procedure for starting materials or components for product manufacture at the contract manufacturer.
QA does not ensure that the test methods of the contract laboratory are validated.
QA's responsibility for procedural instructions, SOPs, GMP documents
Procedural instructions for the following GMP-relevant processes are missing: - batch release - Quality-critical manufacturing processes, operation of production equipment - clarification of deviations in the laboratory (OOS results) - microbiological tests on the end product - Implementation of CAPAs - Dealing with complaints, returns and recalls - Evaluation of changes - Ongoing stability tests - Annual product review
QA responsibility for root cause analysis in case of deviations
Root cause analysis does not take place; instead, unjustified and not scientifically sound corrective measures are taken (e.g. increasing the preservative content ensures that the previously too high microbial count in the product is again in compliance with specifications).
QA responsibility for trained personnel
QA does not take care of the training of staff in quality-critical areas such as processing complaints from customers, returns processing, etc.
This compilation shows: Most violations of basic GMP rules are closely related to the quality unit's failure to take responsibility. Ultimately, the GMP deficiencies associated with the other paragraphs of 21 CRF 211 also result from this failure of quality assurance.
A more detailed analysis of the warning letters of fiscal year 2022 will appear in one of the next issues of the GMP Journal.