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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 Dahiya, SDCO cum Licensing Authority, FDA Haryana
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