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At a high level, GMPs of various nations
are very similar; most require things like:
- Equipment and facilities being properly designed, maintained, and
cleaned
- Standard Operating Procedures (SOPs) be written and approved
- An independent Quality unit (like Quality Control and/or Quality
Assurance)
- Well trained personnel and management
For example, here are the requirements for training from three
different sets of drug GMPs.
U.S.
-
Each person engaged in the manufacture,
processing, packing, or holding of a drug product shall have
education, training, and experience, or any combination
thereof, to enable that person to perform the assigned
functions. Training shall be in the particular operations that
the employee performs and in current good manufacturing
practice (including the current good manufacturing practice
regulations in this chapter and written procedures required by
these regulations) as they relate to the employee's functions.
Training in current good manufacturing practice shall be
conducted by qualified individuals on a continuing basis and
with sufficient frequency to assure that employees remain
familiar with CGMP requirements applicable to them.
[211.25(a)]
-
Each person responsible for supervising the
manufacture, processing, packing, or holding of a drug product
shall have the education, training, and experience, or any
combination thereof, to perform assigned functions in such a
manner as to provide assurance that the drug product has the
safety, identity, strength, quality, and purity that it
purports or is represented to possess. [211.25(b)]
Canada
-
All personnel are aware of the principles of
GMP that affect them, and all personnel receive initial and
continuing training relevant to their job responsibilities.
[C.02.006, interpretation 5]
-
5.1 Training is provided by qualified personnel having regard
to the function and in accordance with a written program for
all personnel involved in the fabrication of a drug, including
technical, maintenance, and cleaning personnel.
-
5.2 The effectiveness of continuing training is periodically
assessed.
-
5.3 Training is provided prior to implementation of new or
revised SOPs.
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5.4 Records of training are maintained.
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5.5 Personnel working in areas where highly active, toxic,
infectious, or sensitizing materials are handled are given
specific training.
-
5.6 The performance of all personnel is periodically
reviewed.
European Union
-
The manufacturer should provide training for all the
personnel whose duties take them into production areas or into
control laboratories (including the technical, maintenance and
cleaning personnel), and for other personnel whose activities
could affect the quality of the product. [EU # 2.8]
-
Besides the basic training on the theory and practice
of Good Manufacturing Practice, newly recruited personnel
should receive training appropriate to the duties assigned to
them. Continuing training should also be given, and its
practical effectiveness should be periodically assessed.
Training programmes should be available, approved by either
the head of Production or the head of Quality Control, as
appropriate. Training records should be kept. [EU # 2.9]
-
Personnel working in areas where contamination is a
hazard, e.g. clean areas or areas where highly active, toxic,
infectious or sensitising materials are handled, should be
given specific training. [EU # 2.10]
-
Visitors or untrained personnel should, preferably,
not be taken into the production and quality control areas. If
this is unavoidable, they should be given information in
advance, particularly about personal hygiene and the
prescribed protective clothing. They should be closely
supervised. [EU # 2.11]
-
The concept of Quality Assurance and all the measures
capable of improving its understanding and implementation
should be fully discussed during the training sessions. [EU #
2.12]
For other topics, there can be differences as to what regulatory bodies
require or expect. For example, in the drug GMPs, the Canadians and
European Union require that internal quality audits be conducted,
however that is not a written in the U.S. cGMPs. (In the U.S., quality
audits are, however, an unwritten expectation of a well-functioning
quality unit.) Another difference is that in Europe and Canada,
"critical" processes and systems are validated; in the U.S., the
FDA requires validation for virtually everything related to drug product
production. |