Key Notes on Revised Schedule M: Point No. 17 – Documentation

Key considerations for Point No. 17 –Documentation for compliance under revised Schedule M are outlined below in the article.

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Key Notes Revised Schedule M 17. Documentation
Key Notes Revised Schedule M 17.
Rakesh Dahiya

Last Updated on January 1, 2025 by The Health Master

Documentation

Key considerations for Point No. 17 –Documentation for compliance under revised Schedule M are outlined below.

Continued from: Key Notes on Revised Schedule M: Point No. 16 – Waste materials

Documentation Requirements for Pharmaceutical Manufacturers

To comply with Good Manufacturing Practices (GMP), pharmaceutical manufacturers must ensure that:

Comprehensive Documentation:

All aspects of manufacturing and control are documented, including specifications, procedures, and records.

Document Design and Control:

  • Documents are designed, reviewed, and approved by authorized personnel.
  • Documents are clear, unambiguous, and easy to understand.
  • Documents are regularly reviewed and updated.
  • Changes to documents are authorized, dated, and signed.
  • Records are made promptly and accurately.
  • Electronic records are secure and backed up.

Labeling:

Labels are clear, unambiguous, and in the company’s format.

Finished products are labeled with:

  • Product name
  • List of active ingredients
  • Batch number
  • Expiry date
  • Storage conditions
  • Directions for use
  • Manufacturer’s name and address

Specifications and Testing Procedures:

Testing procedures are validated.

Specifications are established for:

  • Starting materials
  • Packaging materials
  • Intermediate products
  • Bulk products
  • Finished products
  • Specifications are reviewed periodically.
  • Reference standards and pharmacopoeias are available.

Master Formula Records:

A master formula record exists for each product and batch size.

Records include:

  • Product name and code
  • Dosage form and strength
  • List of starting materials
  • Expected yield
  • Processing instructions
  • In-process controls
  • Storage conditions

Packaging Instructions:

Formally authorized packaging instructions exist for each product.

Records include:

  • Product name and description
  • Pack size
  • Packaging materials
  • Packaging operations
  • In-process controls

Batch Processing and Packaging Records:

Batch processing and packaging records are kept for each batch.

Records include:

  • Product name and batch number
  • Dates and times of processing stages
  • Personnel involved
  • Quantities of materials used
  • In-process control results
  • Yields
  • Deviations from procedures

Standard Operating Procedures (SOPs):

SOPs are available for:

  • Equipment assembly and validation
  • Analytical apparatus and calibration
  • Maintenance, cleaning, and sanitation
  • Personnel matters
  • Environmental monitoring
  • Pest control
  • Complaints, recalls, and returns
  • SOPs for material receipt, storage, and sampling are in place.
  • SOPs for batch numbering and testing procedures are followed.
  • Records are maintained for equipment validation, calibration, maintenance, and cleaning.
  • Cleaning and sanitation procedures are documented and followed.

Compiled by:
Rakesh DahiyaSDCO cum Licensing Authority, FDA Haryana


Next: Key Notes on Revised Schedule M: Point No. 18 – Good practices in production

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