The PIC/S has recently published an Aide-Memoire for GMP inspectors on inspections of quality risk management (QRM) systems that became effectove on 2 April 2012. The document is composed of 10 pages organised in 6 chapters:
The introduction focuses on the importance of a functioning and monitored QA system. A QRM system should be embedded into this QA system.
Chapter 3 defines the purpose of this Aide-Memoire, namely to assist GMP inspectors in the assessment of QRM implementation in industry during regulatory inspections. Moreover, it is pointed out that parts of this Aide-Memoire may also be useful (with suitable modification) during other GxP inspections.
In the scope part, the Aide-Memoire is presented as the current state of the art but is not intended to be a barrier to technical innovation or the pursuit of excellence. This Aide-Memoire mainly relies on the corresponding mandatory articles of Chapter 1 and Annex 15 of the PIC/S GMP Guide as the ICH Q9 Document is not binding for an inspection. The chapter Aide-Memoire expressly defines that dedicated time is required to be allocated to review the QRM system during an inspection.
Chapter 6 should include a revision history. This part is empty as the document has been published for the first time.
The actual Aide-Memoire divides the inspection issues as an annex into 5 sub-chapters:
Conclusion: the PIC/S Aide-Memoire on inspection of QRM systems is very interesting and may be helpful also for the pharmaceutical industry to get fresh perspectives. The document may be used as a checklist for every one's QRM system.
CONCEPT HEIDELBERG (a service provider entrusted by the ECA Foundation)