Key Notes on Revised Schedule M: Point No. 8 – Change Control

Establish a formal system to evaluate all changes affecting product production and control.

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

Last Updated on December 16, 2024 by The Health Master

Change Control

Key considerations for Point No. 8 Change Control compliance under revised Schedule M are outlined below.

Continued from: Key Notes on Revised Schedule M: Point No. 7 – Product Recall

Good Manufacturing Practices (GMP) for Pharmaceutical Products: Change Control

Pharmaceutical manufacturers must adhere to the following principles for effective change control:

Formal Change Control System:

  • Establish a formal system to evaluate all changes affecting product production and control.

Written Procedures:

Develop written procedures for identifying, documenting, reviewing, and approving changes in:

  • Raw materials
  • Specifications
  • Analytical methods
  • Facilities
  • Support systems
  • Equipment (including computer hardware)
  • Processing steps
  • Labeling and packaging materials
  • Computer software

GMP Change Approval:

  • Draft, review, and approve proposals for relevant GMP changes by appropriate organizational and quality units.

Impact Assessment:

  • Evaluate the potential impact of proposed changes on the quality of intermediates, APIs, or finished products.
  • Use a classification procedure to determine the level of testing, validation, and documentation needed to justify changes to validated processes.
  • Employ scientific judgment to determine additional testing and validation studies required for justified changes.

Change Implementation:

  • Ensure all affected documents are revised to reflect implemented changes.

Post-Change Evaluation:

  • Evaluate the first batch produced or tested under the new conditions.

Retest/Expiry Date Impact:

  • Assess the potential impact of critical changes on established retest or expiry dates.
  • Consider accelerated stability programs or additional stability monitoring for samples produced by the modified process.

Compiled by:
Rakesh DahiyaSDCO cum Licensing Authority, FDA Haryana


Next: Key Notes on Revised Schedule M: Point No. 9 – Production under Loan License and Contract Analysis ….coming soon

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