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Essential Good Documentation Practices

The document outlines the importance of Good Documentation Practices (GDP) in ensuring product quality and patient safety, emphasizing compliance with regulatory standards like PIC/S, FDA, and EU GMP. It details requirements for record modifications, documentation types, and communication styles, as well as the significance of maintaining permanent records and adhering to GMP guidelines. Additionally, it discusses packaging, labeling, and storage of pharmaceutical products, highlighting the need for safety and quality assurance in manufacturing processes.

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0% found this document useful (0 votes)
31 views5 pages

Essential Good Documentation Practices

The document outlines the importance of Good Documentation Practices (GDP) in ensuring product quality and patient safety, emphasizing compliance with regulatory standards like PIC/S, FDA, and EU GMP. It details requirements for record modifications, documentation types, and communication styles, as well as the significance of maintaining permanent records and adhering to GMP guidelines. Additionally, it discusses packaging, labeling, and storage of pharmaceutical products, highlighting the need for safety and quality assurance in manufacturing processes.

Uploaded by

hazelmay.sedigo
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Good Documentation Practices

Compliant Record Modifications


Why are Document Standards Important? o​ Corrections must leave original entry visible
o​ Ensure product quality and patient safety o​ Single line strike-through, initial & date
o​ Poor documentation can negatively impact corrections
manufacturing and QA/QC o​ Provide reason for correction if needed
o​ Required by PIC/S, FDA, and EU GMP o​ Omitted data: record both activity & entry dates
o​ Provides: o​ All fields completed (or marked 'N/A')
●​ Information on when, where, who, why, o​ Corrections must be reviewed & signed by
and how tasks are completed checker
●​ Evidence tasks were completed correctly
o​ Critical for audit success Recording Numbers, Dates & Time
o​ Decimals: use leading zero (e.g., 0.98 not .98)
Basic of GDP o​ Follow site procedure for decimal places &
o​ GDP applies to documentation related to: rounding
●​ GMP processes o​ Dates: use clear formats (e.g., 11 March 2012)
●​ Material/product identity, quality, purity, o​ Times: use 24-hour format (e.g., 13:00) or
strength, and safety am/pm
●​ Validated state of manufacturing, facilities,
equipment, systems, testing
o​ Companies should establish GDP policies (e.g., Attachments & Scanned Documents
pen color, scanned documents usage). o​ Attachments must be stapled/taped securely (not
paperclips)
Types of Documents and Records o​ Cross-reference attachments with parent record
o​ Batch Record Forms o​ Thermal printouts must be copied & marked
o​ Bills of Materials (BOMs) 'True Copy'
o​ Specifications o​ Scanned documents allowed if compliant with
o​ Policies, SOPs, Wis, Protocols Annex 11
o​ Test Methods, Checklists, Forms o​ Approval via scanning/signature exchange
o​ Training Assessments, Quality Records permitted
o​ Certificates (CoA/CoC) o​ PDFs accessible, editable files restricted
o​ Validation & Technical Transfer Reports
Communication Styles in GDP
General GDP Requirements o​ Use clear, unambiguous language (avoid jargon)
o​ Clear, accurate, traceable documentation o​ Provide definitions for abbreviations
o​ Use indelible ink, legible handwriting o​ Use whitespace for readability
o​ Entries signed & dated at time of activity o​ Provide enough context for future use
o​ Documents reviewed/approved by independent o​ Use tables, diagrams, visuals where possible
staff o​ Maintain consistent wording & templates
o​ Signatures must be unique & traceable
o​ Delegation of responsibility must be
documented
o​ Page numbering in 'X of Y' format Manufacturing (A043 s 1999)
●​ The complete set of activities to produce a drug
Records Must Be Permanent that comprise production and quality control
o​ Records prove compliance with GMP from dispensing of materials to the release for
o​ Support investigations, CAPA, audits distribution of the finished product
o​ Fraudulent falsification/amendment is prohibited
Pharmaceutical Manufacturing
o​ Records cannot be discarded unless retention
●​ the making by physical, chemical, biological or
expires any other procedure of any article that meets the
o​ Unofficial notes/scrap paper not acceptable definition of drugs
o​ Controlled notebooks/logbooks required ●​ the manufacture, propagation, preparation and
processing of a drug product in a large scale
●​ the manipulation, sampling, testing or control ●​ RA 9711
procedures applied to the final product or any
other part of the process 4. Drug Distributor/wholesaler
●​ the packaging, repacking or changing the ●​ Procures raw materlals, active ingredients and or
container, wrapper or label of any drug package finished product from local establishment or for
in preparation for its distribution from the local distribution on wholesale basis
manufacturer to the final user ●​ RA 9711
●​ mass production of drug products
Departments in a Drug Establishment
Pharmaceutical Manufacturing versus 1. Research Department
Extemporaneous Compounding o​ develops new or existing products

●​ small scale preparation of drug products 3 facilities


●​ prescription order o​ library
●​ specifie for a particular pattent o​ animal house
o​ pilot plant
Drug Establishment
2. Production Department manufacturing of drug
Drug establishment (A056 s 1989) products
●​ Any organization or company involved in the o​ manufacturing of drug products (limited
manufacture, importation, repacking and/or
personnel to prevent contamination)
distributions of drugs or medicines
[Link] Control Department
1. Drug Manufacturer o​ "heart & soul" of a drug manufacturer
●​ any establishment engaged in operations o​ sampling, testing, assaying of drugs
involved In the production of drugs
●​ A056 s 1989
4. Marketing Department
●​ IRR of RA 9711
o​ promotes maximum volume of sales of products
Types:
5. Engineering Department
1.​ Ethical Manufacturers
o​ locates, Installs, repairs and maintains
prescription drugs
equipment
2.​ Proprietary / Generic Manufacturers
o​ ensure plant and personnel safety
branded / generics
3.​ Biologicals Manufacturers​
[Link] Department
vaccines, toxoids, antisera, biotech products
o​ purchases, receives and inventories supplies
4.​ Veterinary Products Manufacturers​
animal drugs
7. Medical Department
5.​ Medicinal Chemical Manufacturers
o​ physical and medical examination of employees
active ingredients, excipients
and applicants
6.​ Toll / Contract Manufacturers
o​ clinical studies
produce drugs for other companies
o​ prepares product inserts and literature
2. Drug Distributor/ Importer/exporter o​ publishes company's newyletter
●​ Imports or exports raw materials, active
ingredients or finished products for Its own use CGMP
or for wholesale distribution on whole sale basis Current Good Manufacturing Practices
●​ IRR 9711 o​ Chapter 21 of the Code of Federal
o​ Regulations Part 211
3. Drug Trader o​ Were first promulgated by the US Food and
●​ registered owner of the drug product but Drug Administration (FDA) in 1963; and
subcontracts toll manufacture of such products finalized in 1979
to a licensed manufacturer
●​ May also engage in distribution and or GMP
marketing of products ●​ Part of quality assurance which ensures that
●​ A056 products are consistently produced and
controlled to the quality standards appropriate to o​ Suitable storage and transport
their intended use
o​ WHO 2007
●​ System of quality assurance aimed at ensuring 4.​ Instructions and procedures are written in an
that products are consistently manufactured to a instructional form in an unambiguous language
quality appropriate for, intended use and is specifically applicable to the facilities provided
concerned with manufacturing and quallty
control process and procedures 5.​ Operators are trained to carry out procedures
●​ A043 s 1999 correctly
●​ Part of quality assurance which ensures that
medicinal products are consistently produced 6.​ Records are made, manually and or by recording
and controlled to the quality standards , intriments, during manufacture which
appropriate to their intended use. demonstrates that all the step required by the
defined procedures and instructions were in fact
Philippine GMP regulation taken and that the quantity and quality of the
●​ A043 1999- adoption of the 1" edition of the product was as expected.
current GMP guidelines by FDA ●​ Any significant deviations are fully recorded
●​ A02012-0008- adoption and Implementation of and investigated
the PIC/s GMP as the standard on the
manufacturer 7.​ Records of manufacture including distribution
●​ FDA MC 2012- Philippine FDA mandated all which enable the complete historyof a batch to
drug manufacturers to ensure strict and full be traced are retained in a comprehensible and
compliance to the newly adopted PICS accessible form

8.​ The distribution (wholesaling) of the products


Chapters of PIC/s GMP 2009 minimizes any risk to their quality

i.​ Quality management 9.​ A system is available to recall any batch of


ii.​ Personnel product from sale or supply
iii.​ Premise and equipment
iv.​ Documentation 10.​ Complaints about marketed products are
v.​ Production examined
vi.​ Quality coritrol ●​ The cause of quality defects investigated and
vii.​ Contract manufacture and analysis appropriate measures taken in respect of the
viii.​ Complaints and product recall defective products and to prevent
ix.​ Self Inspection reoccurence

Basic requirements of GMP (PIC/s2009) PACKAGING, LABELING & STORAGE OF


1.​ All manufacturing processes are clearly defined, DRUGS
systematically reviewed in the light of
experience and shown to be capable of , Packaging
consistently manufacturing medicinal products an economical means of providing presentation,
of the required quality and complying with their protection, preservation, identification, information,
specification containment, convenience and compliance for a drug
product
2.​ Critical steps of manufacturing process and
significant changes to the process validated Container
device that holds a drug and is or may be in direct
3.​ All necessary facilities for GMP are provided contact with the drug
Including Types:
o​ Appropriately qualified and trained
personnel 1.​ Primary Container
o​ Adequate premises and space ●​ aka: Immediate Container
o​ Suitable equipment and services ●​ direct contact
o​ Correct materials, containers and labels ●​ direct effect on the drug
o​ Approved procedures and instruction ●​ bottle, cap, cap liner
2.​ Secondary Container
●​ External to the primary container
●​ Adds physical protection
●​ Carton, boxes, pallets 2. Plastic
●​ does not apply to a single material but rather to a
Classification of Containers vast number of materials each developed to have
desired features
According to Protection Ability Advantages:
o​ lightweight
1. well-closed container o​ flexibility p resistance to Impact
●​ protects against extraneous solids and loss of Disadvantages:
drug under ordinary conditions of handling, o​ permeability
shipment, storage and distribution o​ leaching
2. tight container o​ sorption
●​ protects from extraneous solids, liquids or
o​ transmission of light
vapors, from loss of drug and from
efflorescence, deliquescence or evaporation and o​ alteration of container upon storage
loss of drug under ordinary conditions of
handling, shipment, storage and distribution two types of plastic
3. hermetic container o​ thermoplasic - squeezy
●​ impervious to air or any other gases under o​ thermoses - firm & rigid
ordinary conditions of handling, shipment,
storage and distribution Examples of Plastics
●​ generally sterile
4. light-resistant container o​ Polyethylene (PE)
●​ protects the contents from photochemical cannot be autoclaved
deterioration
●​ amber, opaque, blue o​ low-density (LDPE)
droppers & sprays

According to Quantity Held o​ high-density (HDPE)


solid oral preparations
1. single-unit container
●​ designed to hold a quantity of drug o​ Polyethylene Terephthalate (PET)
Intended for administration as a single dose for beverages
●​ sterility is not assured after opening
●​ ex. ampul, prefilled Syringes o​ APETG (amorphous PET glycol)

[Link]-unit container o​ PETG (PET glycol)


●​ contains more than a single dose of the have transparency and luster gamma radiation
medication sterilization
●​ ex. Vial
o​ Polypropylene (PP)
Materials Used for Packaging Autoclavable

o​ Polyvinyl Chloride
rigid & good clarity blister packaging

[Link]
o​ aluminum, tin & steel
o​ vial caps, ointment, tubes

4. Rubber
o​ synthetic ones are preferred because of their
more definite compositions as compared to
natural rubber
o​ stoppers for vials

5. Paper & Boards


o​ Tissues and boxes

Other Container Materials


Films foils and laminates
o​ Sachet Liner
o​ Seals o​ inserted to the cap to affect a hermetic seal
o​ Strips
o​ Blisters Inner Seal
o​ for more positive seal surface for
Safety Packaging tamper-evidence

1.​ Child-Resistant Container Rubber Stopper


o​ one that is difficult for most children under 5 o​ multiple-dose vials, syringes and gasket aerosols
years of age to open or gain access to the
contents or obtain a harmful amount of the Coil
contents o​ to prevent damage during shipping

2.​ Tamper-Resistant Container Desiccant


o​ uses an indication or barrier to entry that Is o​ to absorb moisture
distinctive by design, or must employ an
Identifying characteristic which if “ breached or Package Insert
missing” can reasonably be expected to provide o​ contains essential information about the product
visible evidence to consumers that tampering
has occurred

o​ Tamper-Resistant Container
o​ Film wrappers
o​ blister/strip packs
o​ bubble packs o shrink seals/bands
o​ foil
o​ paper or plastic pouches
o​ bottle seals
o​ tape seals
o​ breakable caps
o​ sealed tubes
o​ sealed cartons
o​ aerosol containers
o​ cans

Storage Temperatures of Pharmaceutical Products

Common questions

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The Quality Control Department is pivotal in a drug establishment as it ensures all aspects of manufacturing comply with quality standards . It performs critical functions such as sampling, testing, and assaying of drugs to verify product identity, strength, purity, and safety, ensuring every batch released into the market is fit for consumption . This department also investigates discrepancies and rejects defective products, preventing them from reaching the consumer . It is considered the "heart & soul" because the integrity and efficacy of pharmaceutical products hinge on its vigilance and rigorous assessments, underpinning the trust in drug safety and effectiveness .

Poor documentation practices in pharmaceutical manufacturing have significant ethical implications as they can jeopardize product quality and patient safety, which are paramount in the industry . Inadequate or inaccurate documentation could lead to incorrect manufacturing processes, resulting in defective products that compromise patient health. Additionally, such practices can result in non-compliance with regulatory standards, leading to legal ramifications and loss of trust from consumers and regulatory bodies . Ethically, manufacturers are obliged to ensure transparency, traceability, and reliability in documentation to uphold patient safety and public health standards .

The key elements of Current Good Manufacturing Practices (cGMP) as adopted by the Philippine FDA include quality management, personnel, premise and equipment, documentation, production, quality control, contract manufacture and analysis, complaints and product recall, and self-inspection . These elements ensure all manufacturing processes are well-defined, validated, and executed under controlled conditions with adequately trained personnel and suitable facilities. Documentation provides traceability, and thorough quality control ensures defects are prevented and addressed. These practices collectively ensure consistent production of pharmaceuticals that meet safety and efficacy standards, thereby assuring product quality .

Pharmaceutical manufacturing involves large-scale production of drugs, ensuring they meet regulatory standards for quality, purity, and safety . This encompasses complex procedures like manufacturing, packaging, and testing on a massive scale. In contrast, extemporaneous compounding is small-scale and involves preparing drug products based on a specific prescription for an individual patient, emphasizing customization over mass production . The purpose of manufacturing is to produce standardized products for widespread distribution, while compounding focuses on meeting specific needs of individual patients .

Compliant record modifications are crucial in maintaining the integrity of pharmaceutical documentation, as they ensure transparency and traceability in data handling . Corrections must leave the original entry visible, with a single line strike-through, initialed, dated, and sometimes with the reason for correction specified . This process prevents data falsification and ensures that records accurately reflect manufacturing activities, aiding in audits and investigations. Non-compliance or improper record modifications could lead to misinterpretations, compromising quality control and patient safety . Thus, rigorous adherence to compliant modification practices underlines the ethical responsibility and regulatory compliance required in pharmaceutical manufacturing .

Well-closed containers protect against extraneous solids and prevent the loss of products under normal handling, shipment, storage, and distribution conditions . They provide a basic level of protection. Tight containers offer enhanced protection by additionally preventing the entry of liquids, vapors, efflorescence, deliquescence, and evaporation under the same conditions . Hermetic containers provide the highest level of protection, being impervious to air or other gases and often used for sterile products . These differences ensure varying degrees of product stability and integrity depending on the specific needs of the pharmaceutical product .

Drug Traders are responsible for owning drug products and subcontracting their manufacture to licensed drug manufacturers . They play a significant role in marketing and distribution, often without directly engaging in production. Instead, they coordinate with contract manufacturers for product production while controlling branding and sales strategies . Their interaction with manufacturers is integral to ensuring regulatory compliance and maintaining supply chain continuity and efficiency, as they must ensure that the manufacturing processes meet quality standards and business objectives . This collaboration ensures that products are produced consistently and are ready for market distribution .

Primary containers, also known as immediate containers, have direct contact with the drug and directly affect the drug's quality by providing presentation, protection, and preservation . They include bottles, caps, and liners. Secondary containers are external to primary containers and add an additional layer of physical protection, serving functions like containment, convenience, and compliance without directly contacting the drug . Examples include cartons and pallets, which protect primary containers during handling and storage .

Critical components of Good Documentation Practices (GDP) include ensuring documents are clear, accurate, and traceable, utilizing indelible ink, and ensuring entries are signed and dated at the time of the activity . These practices are crucial for audit success as they provide evidence that tasks are completed correctly, maintain compliance with regulatory requirements such as PIC/S, FDA, and EU GMPs, and support investigations, CAPA, and audits . GDP also ensures product quality and patient safety by providing a detailed record of manufacturing processes, thereby safeguarding against errors and non-compliance .

Drug establishments are categorized based on their operations in the production, distribution, and sale of pharmaceuticals . They include Drug Manufacturers, who directly engage in drug production and may specialize in prescription drugs, generics, biologicals, veterinary products, medicinal chemicals, and contract manufacturing . Drug Distributors handle the import, export, and local wholesale distribution of pharmaceutical products . Drug Traders own drug products but subcontract manufacturing to licensed manufacturers and may be involved in the marketing and distribution of these products . Each type of establishment supports different stages in the drug supply chain, providing either direct manufacturing or facilitating distribution and marketing .

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