Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
Risk Concept
QRM Fundamentals
Regulatory Expectations – Warning Letters /
Observations
Application of QRM
Introduction: Foundation of Risk Assessment –
Q8(R), Q9, Q10
Investigational Products
GMP
Management Responsibilities
Knowledge Management
Enablers
Quality Risk Management
3
Primary Tenant of Risk Management in ICH Q9
Appropriate use
of quality risk
management
can facilitate but
does not obviate
industry’s
obligation to
comply with
regulatory
requirements…
What is Risk ?
Some Key Terminology
Harm: Damage to health, including the damage that can occur from loss of
product quality or availability. (ICH Q9)
Residual Risk: Risk remaining after risk control measures have been taken.
(ISO 14971)
Medication or Manufacturing
Known Side Effects
Device Error Defects
Avoidable Unavoidable
Preventable
Adverse
Events
Injury or Unexpected
Death Consequence
Source: adapted from FDA (1999). Managing the Risks from Medical Product Use.
What is Quality Risk Management
QRM
What are the Benefits:
RISK ANALYSIS
RISK ASSESSMENT
Intended use and identification of
characteristics related to the
safety of the medical device
Identification of hazards
Estimation of the risk(s) for each
hazardous situation
RISK EVALUATION
RISK CONTROL
RISK MANAGEMENT
Risk control option analysis
Implementation of risk control
measure(s)
Residual risk evaluation
Risk/benefit analysis
Risks arising from risk control
measures
Completeness of risk control
PRODUCTION AND
POST-PRODUCTION INFORMATION
ICH Q9 Principles of QRM
Transparent system
RISK ASSESSMENT-IDENTIFICATION/ANALYSIS/EVALUATION
RISK REVIEW-REVIEW EVENT /PRODUCTION AND POST PRODUCTION INFORMATION/ REVIEW MITIGATION PLANS
High Recalls
Notification to
Mgt Shipping
Packaging & Computers
Audits Global Change
Labelling
Control
Operations
Quality Mgt.
Tech Transfer
CAPA Local Change Control
Severity of Risk
Training
Complaints
Validation
Deviations
Vendor Mgt.
Sampling &
Batch Release Documentation
Testing
Planned Maintenance
& Calibration
Mfg. Procedures & Controls
Packaging & Labelling
Environmental Controls &
Components
Monitoring
PQRs/APRs
Stability
Qualitative
– Use risk categorisation to assess risk potential, e.g. Risk
Checklists
Quantitative
– Use data based on scientific understanding to determine
probability & impact
– Use Statistical Techniques or Simulations
RA Tool Comparison
Adverse Event - Front Line Tool
2. Problem Statement (Brief statement clearly describing the problem to be resolved) 6. Proposed Counter Measures (Proposed actions to address each root cause)
8. Follow Up Actions
Who What When
Risk Considerations in Aseptic Processing
RISK ASSESSMENT RISK REDUCTION
Risk Reduction
Wet Seving Temperature Not meet specificaion of 2 4 1 8 Implement two temperature 1 1 1 1 7 Automatically interruption by not
Drying degradation measures meeting range; Temperature
monitoring in batch record
Granulation Water Content Not meet specification 2 3 1 6 - Introduce online NIR 2 1 1 2 4 - Indirect Measurement
Drying of degradation - Introduce IPC Analytic 2 2 1 4 2 - Direct Measurement; Time
Consuming
- Humidity measurement in - Indirect Measurement;
2 1 2 4 2 Unspecific
the exausting air
Granulation Kneeding Time Not meet specification 3 3 1 9 Reduce personnel 3 3 1 9 0 Operator knowledge; depending
of degradation fluctuation on power consumption;
automatisation not possible at
that time
Granulation Power Not meet specification 3 2 1 6 Try to get to a minimum an 3 2 1 6 0 Depending on kneeding time
Consumption of disolution optimum of kneeding time depending on material
properties
Pre Mixing Mixing time Not meet specification 3 2 3 18 IPC measure on content 3 2 1 6 12 Influence on efficacy
of content uniformity uniformity
Pre-Mixing Speed of Adding Not meet specification 3 3 3 27 Analyse (seeving of 3 2 1 6 21 To ge fine appropriate granulate
Granulation Water of disolution and granulate sieve analysis);
desintegration use of dosage pumps
Pre-Mixing Manner of Not meet specification 3 1 1 3 Install spray nozzles 1 1 1 1 2 To get fine appropriate
Granulation Adding Water of disolution and granulate
desintegration
Granulation Quality of All paramaters have to 3 4 3 36 Adapt internal specification 1 2 2 4 32 Contract Supplier
Excipients be re-evaluated of physical parameters (e.g.
deensity, metability,
Granulation Quality of API All paramaters have to 3 4 3 36 1 2 2 4 32 Contract Supplier
be re-evaluated wetability)
FMEA
FTA
HAZOP
Complexity
HACCP
PHA
REM
CM
Formality
A quotation I like
Michael Kerr
C&Q Dept Manager
PM Group
Email: michael.kerr@pmgroup-global.com
Tel: +353 21 435 8922