Key Notes on Revised Schedule M: Point No. 2 – Quality Risk Management

Key considerations for Point No. 2 - Quality Risk Management (QRM) compliance under revised Schedule M are outlined in the article.

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Key Notes Revised Schedule M
Key Notes Revised Schedule M
Rakesh Dahiya

Last Updated on December 14, 2024 by The Health Master

Quality Risk Management

Key considerations for Point No. 2 Quality Risk Management (QRM) compliance under revised Schedule M are outlined below.

Continued from: Key Notes on Revised Schedule M: Point No. 1 – Pharmaceutical Quality System

Quality Risk Management

Pharmaceutical manufacturers must adhere to these guidelines to ensure Good Manufacturing Practice (GMP) and produce high-quality drugs.

Systematic Process:

QRM is a systematic process to assess, control, communicate, and review risks to product quality.

Proactive and Retrospective:

It can be applied both proactively (beforehand) and retrospectively (after an issue).

Risk-Based Approach:

The level of effort, formality, and documentation of the QRM process should be commensurate with the level of risk.

Patient Protection:

Risk evaluations should be based on scientific knowledge, experience, and ultimately link to protecting the patient.

Product Quality Review:

Regular Reviews:

Regular, periodic, or rolling quality reviews of all pharmaceutical products should be conducted.

Review Scope:

Reviews should include:

  • Starting and packaging materials, especially from new sources
  • Critical in-process controls and finished product results
  • Failed batches and investigations
  • Significant deviations, non-conformities, and corrective actions
  • Changes to processes or analytical methods
  • Dossier variations
  • Stability monitoring results
  • Returns, complaints, and recalls
  • Adequacy of previous corrective actions
  • Post-marketing commitments
  • Equipment and utility qualification and monitoring
  • Technical agreement updates

Corrective Actions:

The results of the review should be evaluated, and corrective and preventive actions should be taken as needed.

Documentation and Verification:

Procedures for managing and reviewing corrective actions should be documented and verified during self-inspections.

Technical Agreements:

Technical agreements should be in place between parties involved in the review, defining their responsibilities.

Authorized Person Responsibility:

The authorized person responsible for final batch certification should ensure timely and accurate quality reviews.


Compiled by:
Rakesh DahiyaSDCO cum Licensing Authority, FDA Haryana


Next: Key Notes on Revised Schedule M: Point No. 3 – Good manufacturing practices for pharmaceutical products

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