Quo vadis GMP?

The USA have already made suggestions for updating the US-American GMP rules through their initiative "cGMP for the 21st Century". But what about Europe? The EC GMP Guide Part I dates back to the 80s. Part II (ICH Q7) is a product of the 90s. Even these two parts show obvious differences in comparable chapters. Revisions of various annexes have been conducted until today or are pending (e.g. Annexes 2 and 11). Changes have also been made to some chapters of the Guide itself (e. g. introduction of the Product Quality Review and of Risk Management in Chapter 1).

What comes next?

Perhaps the new GMP Guide of the Canadians could give us a hint to this? As a PIC/S member country and also as a country with a Mutual Recognition Agreement on GMP with the EU, Canada's GMP rules should also be of interest to the EU. Quite recently (8 May 2009) the Canadians' new GMP Guide was published. It comes into force on 8 November 2009. Details on the changes with regard to the original version of 2002 can be found here.

The now very comprehensive Guide consists of 102 pages (including 4 appendices, acronym list, glossary and references) in PDF format and has a slightly different structure than the EC GMP Guide. The manufacture of sterile medicinal products has e.g. been directly integrated into the Guide. The contents, however, are quite similar to those of Annex 1 (sometimes even the wording is identical).
The following list represents the table of contents of the 2009 version of the Canadian GMP rules:


1.0 Introduction
2.0 Purpose
3.0 Scope
4.0 Quality Management
4.1 Guiding Principle
4.2 Relationship among Quality Elements
4.2.1 Quality Assurance
4.2.2 Good Manufacturing Practices (GMP) for Drugs
4.2.3 Quality Control .
5.0 Regulation
     Raw Material Testing
     Manufacturing Control
     Quality Control Department
     Packaging Material Testing
     Finished Product Testing
     Sterile Products
     Medical Gases
Appendix A Internationally Harmonized Requirements for Batch Certification
Appendix A1 Content of the Fabricator's/Manufacturer's Batch Certificate for Drug/Medicinal Products Exported to Countries under the Scope of a Mutual Recognition Agreement (MRA)
Appendix B
     Glossary of Terms
Appendix C Annexes to the Current Edition of the Good Manufacturing Practices (GMP) Guidelines
Health Products and Food Branch Inspectorate - Operational Centres

The structure of the Canadian GMP Guide is very helpful for the reader, since - apart from the actual regulation - he or she also finds the corresponding rationale for this regulation as well as its interpretation. The requirements on equipment are e.g. described in a concise manner (cleanable, not contaminating the product, functional). The rationale then explains among others which types of contamination (dust, rust …) can occur for which reasons (misuse of the equipment, poor maintenance …). Finally, the interpretation requires among other things that validated CIP equipment must be easy to dismantle for periodic verification. Such detailed requirements cannot be found explicitly e.g. in the EC GMP Guide.

In the following you will find some examples for notable features of the new Canadian GMP rules:

  • For the identity testing of raw materials, a composite sample from 10 containers at the most is acceptable if a potency test is performed on this composite sample taking account of the mass balances. These concrete specifications are not to be found like this in the EC GMP Guide.
  • The responsibility for the timely performance of the annual Product Quality Review lies with quality control. This is certainly due to the fact that there is no Qualified Person defined in the Canadian regulations.
  • Archived documents have to be accessible within 48 hours. Such a concrete requirement cannot be found in the EC GMP Guide.
  • Metal surfaces of water systems should at least have "316 stainless steel" quality and should be passivated. We do not know such concrete requirements on water systems in official regulations in Europe.
  • The extent of revalidation work on water systems should be determined jointly by staff from quality control, engineering, production and further involved departments. In this context, the EC GMP Guide does not include such a concrete list of departments either.

Conclusion: The new Canadian GMP Guide is indeed worth reading and also provides detailed information on general GMP rules. In this respect, it could also give guidance to European firms where national or European GMP legislation does not specify any details. Naturally, this document is not legally binding for European companies.

Does it indicate where GMP is heading? For this, the alterations seem too moderate. From this perspective, the document rather represents a rung on the ladder of GMP evolution and may be seen as the Canadian authority's contribution to the Darwin anniversary year.
Here you can find the 2009 version of the Canadian GMP rules.

Are you interested in GMP evolution? Get to know all the essential innovations in this field at the 3rd European GMP Conference in Heidelberg, Germany, on 23-24 June 2009.

Sven Pommeranz
On behalf of the European Compliance Academy

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