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Prepared by:
Approved by:
ASEAN TMHS GMP Task Force
30 November 2016
Endorsed by:
ASEAN TMHS Product Working Group
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements
(TM/HS)
CHAPTER 5 - DOCUMENTATION
Brunei Darussalam and Lao PDR
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
ACKNOWLEDGEMENT
We would like to thank the following review team for their
input to this training module.
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Muhammad Lukmani Ibrahim
Chair of ASEAN GMP
TF
Quitevis, Ludivina Fama
Co-Chair of ASEAN
GMP TF
Mega Valentine ASEAN Secretariat
Hasmilawaty Mohammad Taib Brunei Darussalam
Jamilah Metusin Brunei Darussalam
Hean Kimseat Cambodia
Som Samnang Cambodia
Kristiana Haryati Indonesia
Widiastuti Adiputra Indonesia
Bounleuane Douangdeuane Lao PDR
Solivanh Sengchanh Lao PDR
Sivong Sengaloundeth Lao PDR
Mohd Nasrul Mohamad Noor Malaysia
Sharifah Mastura Ahmad Fuad Malaysia
Thiri Kyaw Soe Myanmar
Wah Wah Aung Myanmar
Mary Angeline V. Francisco Philippines
Ms. Rochel Averion Francisco Philippines
Ong Hai Ann, Terrance Singapore
Pinpong Intarapanich Thailand
Thida Thaveerit Thailand
Lam Quoc Hung Vietnam
Luu Duc Du Vietnam
Mak Sum Shing, Andrew AAHSA
Tamotsu Iwai AAHSA
Robles, Frances Evelyn AATMI
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
OUTLINE
• Objective
• Purpose
• Principle
• General Guidelines
• Quality Control Documents
• Specifications
• Production Documents
• Packaging Instructions
• Batch Manufacturing Records:
– Processing
– Packaging
• Standard Operating Procedures and Records
• An example of Document Format
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
OBJECTIVE
• An essential element of quality assurance is good
documentation practices.
• The system of documentation devised or adopted should have
as its main objective to establish, monitor, and record
“quality” for all aspects of the production, quality control and
quality assurance.
• Record provides evidence of work done.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
PURPOSE
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• Clearly written documentation prevents errors that may arise
in oral or casually written communication
• It provides assurance that quality related activities are carried
out exactly the way they have been planned and approved
• The achievement of conformity and quality improvement
• Purpose of documentation :
• To ensure that there are specifications for all materials and
methods of manufacture and control
• Employees know what to do
• Responsibilities and authorities are identified
• Ensure that authorized persons have all information necessary
for release
• Provide audit trail
• Forms the basis for improvement.
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
PRINCIPLE
• Good documentation constitutes an essential part of the quality
assurance system and should exist for all aspects of GMP.
• Clearly written documentation prevents errors from spoken
communication and permits tracing of batch history of the product,
from purchasing of starting materials to the distribution of finished
products.
• It shall be able to record executed activities for maintenance, storage,
quality control, distribution and other specific matters linked to GMP.
• For manufacturing activities, a documentation system must be
prepared.
• The system consisting of manufacturing formulae and instructions,
specifications, procedures and records must be free from errors and
clearly established.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
GOOD DOCUMENTATION PRACTICE
GENERAL GUIDELINES
• The system of documentation shall be:
– able to record the complete history of each batch.
– adequate to permit investigation and tracing of any defective products.
• Documents shall contain all necessary information, to be kept up to
date and any amendment shall be performed by following proper
document change control procedure and authorised. It shall
include provision for periodic review and revision as necessary.
• Product related records shall be retained for at least one year after
the expiry date of the finished product.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
GOOD DOCUMENTATION PRACTICE
GENERAL GUIDELINES
Documents shall:
– be designed, prepared and laid out in an orderly fashion
– be written in detail and in simple language that can be easily understood by
the user
– have unambiguous contents
– have title, nature and purpose shall be clearly stated
– not be hand-written
– be regularly reviewed and kept up to date
– prevent inadvertent use of superseded documents, when they have been
revised
– be approved, signed and dated by an authorised person
– be distributed with care
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
Reproduced documents shall:
– be clear, legible and duly authorised.
– not allow any error during the reproduction of documents
Records shall:
– be made in clear, legible, and indelible handwriting. Sufficient space
shall be provided for such entries.
– be signed and dated, and where appropriate the reason of the
alteration to be recorded when any alteration made to the entry on a
document. The alteration shall permit the reading of the original
information.
– be made or completed at the time each action is taken and in such a
way that all significant activities concerning the manufacture the
product are traceable.
– be readily available throughout the period of retention.
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GOOD DOCUMENTATION PRACTICE
GENERAL GUIDELINES
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
GOOD DOCUMENTATION PRACTICE
GENERAL GUIDELINES
Electronic Data :
Data may be recorded by electronic systems, photographic or other reliable
means, but there shall:
– be detailed procedure (e.g. SOP) relating to the system in use
– be checked and verified for accuracy of the records
– be authorised personnel to enter or modify data in the computer
– be a record of changes and deletions
– be traceability to all raw data
– be restricted by passwords or other means for access
– be independently checked and verified for the result of entry of critical
data
– be protection and back-up for all batch records.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
GOOD DOCUMENTATION PRACTICE
GENERAL GUIDELINES
• The manufacturer shall practice what is documented in the written
procedures.
• Under circumstances where there is a change in the practice, the
written procedures shall be promptly updated.
• If a written procedure was revised, appropriate training shall be
provided to ensure that the personnel carry out the work in
accordance to the revised procedure.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
TIERS OF DOCUMENTATION
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Broadly, all documents relating to
quality fall in to the following
categories:
 Quality Manual (optional)
 Procedures (QSP and SOP)
 Work Instructions (can be
merged with Procedures)
 Records
Legend:
QSP - Quality Standard Procedure
SOP - Standard Operating Procedure
All levels are integrated to form a comprehensive and cohesive documentation
network via a system of cross referencing
Records
Work Instructions
Procedures
Quality
Manual
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
TIERS OF DOCUMENTATION
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QM
QSP #03
QSP #02
STANDARD
PROCEDURE
QSP #01
QUALITY
MANUAL
(optional)
WI #03
WI #02
WORK
INSTRUCTION
WI #01
WP #03
WP #02
WORK
PROTOCOL
WP #01
STD #03
STD #02
STANDARD
TEST /
SPECIFICA-TION
STD #01
CE #03
CE #02
CODE
ETHICS /
WORK
POLICY
CE #01
IL #03
IL #02
IDENTITY
LABELS
IL #01
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
QUALITY MANUAL (OPTIONAL)
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The strategic document that outlines the organization’s system of providing
quality assurance to achieve customer satisfaction.
Objectives :
 Describe the quality system structure
 Declare the quality policy and organization goal
 Describe how the organization meets the quality goal
Content of quality manual :
 The quality policy declaration
 The goal of quality;
 The organisational structure including
responsibility and authority of each key
personnel
 Procedures, instructions and resources for
implementing the quality management.
User :
 All personnel in the organization
 Another parties, auditors, and customers
Records
Records
Work Instructions
Procedures
Quality
Manual
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
PROCEDURES
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The tactical document that outlines the activities or operations of the
organisation in implementing the stated quality policies.
Objectives :
Describe in detail how activities should be done, controlled and
recorded in implementing the definite policy
Standard Operating Procedures explains:
 What the process is and it’s purpose
 Where activity is operating
 Who is responsible for every activity
 When activity is completed, sequential of
the activities, frequency, etc.
 How activity can be finished follow the work
instruction design or other reference
documents
 Reference to the other relevant documents
User :
 All personnel who set up and run the
processes
Records
Work Instructions
Procedures
Quality
Manual
Procedures
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SUPPORTING DOCUMENTS OR
WORK INSTRUCTIONS
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The operational document containing instructions specifying how the
activities are performed or products are accepted.
Records
Procedures
Quality
Manual
Objectives :
 It is an instruction document, step by step for guideline
to execute the daily activity or operation for personnel in
every function
 It is used departmentally, every task or every line.
Content of work instructions :
 Detailed explanation of instructions to finish
the job, detailed handling of method,
equipment and machine
 Related to the technical matters with stressing
for operation, inspection & testing.
User :
 All personnel who operates the certain task
Supporting documents:
 Worksheet, checklist
 Visual (illustration, flow chart, layout plan,
photo)
Work Instructions
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
S.O.P. versus W.I.
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 Process oriented
 Describe step of procedure
 Supporting the Quality Manual
 Explain general description on
certain process and give
systematic action to ensure
product quality
 Procedure guideline which
involve several departments
and/or sections
 During implementation need
other supported documents
 Guideline at organization level
QUALITY PROCEDURE/SOP
 Task oriented
 Describe detail instruction
 Operation guidance
 Dedicated to explain special task,
method, or technique which
should be done to achieve target
quality
 Instruction guidance which
dedicated for certain department
or section only
 During implementation can stand
alone
 Guidance at operational level
WORKING INSTRUCTION
SOP and WI can be merged depending on the documentation system adopted by the company
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
RECORDS
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Records, including charts and data pertaining to design, inspection, testing,
survey, audit, review or related results, should be maintained as important
evidence to demonstrate:
 Quality System has been effectively
implemented;
 that products and services have been
developed and delivered appropriately with the
requirements.
All Records should be :
 legible and clear;
 Dated;
 readily identifiable and retrievable;
 carry authorisation status;
 retained for a designated period;
 protected from damage and deterioration while
storage.
 All calculations should be duly recorded
Work Instructions
Quality Procedures
Quality
Manual
Records
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
FORMAT OF DOCUMENT
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 No “best format” in documentation system.
 Each document should be suitable for all users
 In general, all quality documents can be written in the
following format :
 narrative
 flowchart
 combination narrative and flowchart
 electronic / computerized system
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
DOCUMENT NUMBERING SYSTEM
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Every document shall have a unique number
• to facilitate traceability
• Yet simple to facilitate saving and controlling of the
document
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
CONTENT OF DOCUMENT
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What should be written in the document:
• Name of document
• Name of company, department or division of the maker
• Document number
• Revision number
• Page and number of pages of document
• Date of approved
• Effective date
• Name and signature of the person who prepared the document
• Names and signatures of the person who reviewed and person
approved the document
• Content of procedure/instruction
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
NARRATIVES DOCUMENT
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• The most common format being used
• The narrative document can be described as the following:
 Policy reference
 Objective : why and for what
 Coverage area
 Document reference
 Responsible person
 Detail procedure
 Record if needed
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
FLOWCHART DOCUMENT
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Schematic representation which describe the flow of
processes in certain target activity
Very clear and easy to understand
Sample of the flowchart document can be written as
beside schema
For complicated process, sometimes flowchart alone
might not be able to capture detailed information
therefore it should be combined with a narrative
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
Incoming Packaging
Material
Quality Control
Sampling / Testing
Incoming Starting
Material
Quality Control
Sampling / Testing
Dispensing
Mixing
In Process Quality
Control
Filling
In Process Quality
Control
Packaging /
Cartoning
Finished Product
Quality Control
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Typical
Production
Flowchart
Rejected
Failed
Passed
Rejected
Failed
Warehouse
Passed
Rejected
Rejected
Passed
Passed
Failed
Failed
Rejected
Failed
Passed
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
COMBINED DOCUMENTS
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Sometimes narrative document and flowchart are also
supported by design/lay out
Legend
1 = Mixer
2 = Intermediate bin with activated discharge
3 = Feed metering unit
4 = Metal separator
5 = UPZ fine impact mill with pin discs
6 = UPZ fine impact mill with pin discs
7 = Automatic reverse-jet filter
8 = Fan
9 = Rotary valve
10 = End-product bin with activated discharge
11 = Bagging unit
12 = Control cabinet
A = Feed product
B = Perfume addition
C = End product
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
DOCUMENT CONTROL
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As mentioned in the previous slides, documents shall:
• Be approved, signed and dated by appropriate authorised
persons
• Be properly authorized before making any change
• Records shall be made or completed each time action is taken
in such a way that all significant activities concerning the
manufacture of the product are traceable
• There shall also be a way to differentiate master hard copy
document from all duplicated copies (e.g. stamp “MASTER
WHEN RED” on master copy and stamp “CONTROLLED COPY”
on distributed copies)
• Distributed documents should be recorded (e.g. using
distribution list)
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
DOCUMENT CONTROL
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• Obsolete documents:
• Control copies shall be retrieved from users based on
distribution list and properly destroyed to prevent
inadvertent use
• Obsolete master documents shall be marked “obsolete”
and archived
• Create a list/index of all documents established
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
DISTRIBUTION OF DOCUMENTS
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• Only up-to-date documents shall be distributed
• Copy of documents should be distributed to relevant parties
and available at point of use e.g. Processing and Packaging
Instructions should be available in Production Areas
whereas Test Methods shall be available in QC labs
• Only document Controller or QC/QA are authorised to
distribute the document in accordance to written procedure
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
REVIEW AND REVISION OF
DOCUMENTS
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• Documents shall be reviewed periodically to confirm that they
are up to date.
• Changes to the procedures/steps on the document shall go
through the proper change control and approved by an
authorised person
• The newly revised documents shall state:
• The date of revision
• Reason for the revision
• The new effective date
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
RECORD KEEPING RULES
“Do Not” Rules
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• DO NOT leave any blanks in forms (shall indicate “nil” or
“N/A” when there is no legitimate entry)
• DO NOT leave mistakes uncorrected (check your entries)
• DO NOT scribble out mistakes (shall not obscure original
entries)
• DO NOT write correct entries over incorrect entries (writing
over shall not obscure original entries)
• DO NOT forget to initial and date entry
• DO NOT use pencil (all entries should be made using
permanent ink)
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
LIST OF DOCUMENTS REQUIRED
1. Quality Control Documents
2. Production Documents
3. Standard Operating Procedures (SOPs) and Records
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Chapter 5 - Documentation
QUALITY CONTROL DOCUMENTS
• Must be readily available from Quality Control Dept.:
– Specifications:
• Natural materials
• Starting and packaging materials
• Intermediate and bulk products
• Finished products (FP)
– Sampling Procedures
– Testing Procedures and records (incl. analytical worksheets and/or
laboratory notebooks)
– Analytical reports and/or certificates
– Data from environmental monitoring, if appropriate
– Procedures for and records of calibration of instruments and
maintenance of equipment
• Any QC documentation (e.g. test records, data, reports, etc)
relating to batch record – retained at least one year after
expiry date of Finished products
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Chapter 5 - Documentation
QUALITY CONTROL DOCUMENTS
Specifications:
– Describe the required characteristics or composition of a
product or material or test, while test procedure is required
to evaluate the specific quality attributes
– Provide the specific details defining the quality of:
• Natural materials
• Starting material
• Packaging materials,
• Intermediate and bulk products
• Finished products
– All specifications should be approved by authorised
personnel (QC/QA manager)
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS – NATURAL MATERIALS
Where appropriate the content shall include for :
− Scientific name and if possible with reference to the authors.
− Details to the source of the natural material (country or region of origin,
cultivation, time of harvesting, collection procedures, possible pesticides
used, etc.).
− Whole plant/animal or only a part material is used.
− When dried plant/animal, drying system shall be specified.
− Pictorial demonstration macroscopical and/or microscopical examination
− Storage condition and shelf life where applicable
Annex 1 – Specification for Foeniculi vulgare
Assurance for materials from animal parts origin should be free from
undesirable disease (e.g. Transmissible Spongiform Encephalopathy).
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS – NATURAL MATERIALS
Testing procedures shall be available if the following tests
are conducted (where appropriate):
– Identifications tests (incl. active constituents, known markers)
– Assay (known therapeutic activity or markers where possible)
– Limit tests e.g. Ash value, presence of essential oils, loss on
drying
– Test for heavy metals and likely contaminants, foreign materials
and adulterants
– Tests for radioactivity, mycotoxin, fungal and microbial
contamination
– Tests for residual solvents in extracts or Finished Products (if
applicable)
– Other tests, as required.
Annex 2 – Text Method for Foeniculi vulgare
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS – STARTING MATERIALS &
PACKAGING MATERIALS
• All Starting and Packaging Materials specifications
should consist of the following data, where applicable:
– Description of the material
Designated name of material & internal code reference
Reference, if any, to pharmacopoeia monograph
Name of approved suppliers, and if possible, original producer of the
products
Specimen of printed materials, including colour
Microbiological standards, if any;
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS – STARTING MATERIALS &
PACKAGING MATERIALS
Where appropriate the content shall include for :
• directions for sampling and testing or reference to
procedures;
• qualitative and quantitative requirements with
acceptance limits;
• storage conditions and precautions; and
• the maximum period of storage before re-examination
• Assurance for materials from animal parts origin should be
free from undesirable disease (e.g. Transmissible
Spongiform Encephalopathy).
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Annex 3 – Specification for Ascorbic Acid
Annex 4 – Test Method for Ascorbic Acid
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS
– INTERMEDIATE AND BULK PRODUCTS
• Specifications for intermediate and bulk products,
− shall be available if purchased or transferred,
− or if data obtained from intermediate products are
used for the evaluation of the finished product
− the specifications shall be similar to specifications for
starting materials or for finished products
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS – FINISHED PRODUCTS
All specifications of finished products should describe the
following:
• Designated name of product (and internal code reference where
applicable);
• Formula or a reference to;
• Description of dosage form and package details;
• Directions for sampling and testing or reference to procedure
where applicable;
• Qualitative and quantitative requirements with acceptable limits
where applicable;
• Storage condition and any special handling precautions, where
applicable;
• Shelf-life or expiry date.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
SPECIFICATIONS – FINISHED PRODUCTS
Specifications for finished products (contd.):
− Qualitative and quantitative requirements, with the
acceptance limits, where applicable:
 Physical appearance such as colour, taste, texture,
size, etc;
 Uniformity of weight (for tablets and capsules),
disintegration (for tablets, capsules and pills),
hardness and friability (for tablets), and viscosity
(for internal and external liquids);
 Heavy metals limits;
 Microbial limits;
 Other tests, as required, such as preservatives
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
OTHER QUALITY CONTROL DOCUMENTS
For other Quality Control Documents (e.g. Sampling
Procedures, Testing Procedures and records,
Analytical reports and/or certificates) please refer to
the details Chapter 7 – Quality Control
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
PRODUCTION DOCUMENTS
– Manufacturing Formula and Processing Instructions
– Packaging Instructions
– Batch Processing Records
– Batch Packaging Records
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
PRODUCTION DOCUMENTS
– MANUFACTURING FORMULA
Formally authorised Manufacturing Formula and Processing
Instructions should be available for each product and batch size to be
manufactured and often they are combined in one document
Shall include:
• Product name with reference code relating to its specification
• Description of product dosage form and strength, and batch size
• List of all starting materials
– Amount of each
– Designated name and reference which is unique to the material
– Substance that may disappear during processing
• Statement of expected final yield with acceptance limits.
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Chapter 5 - Documentation
PRODUCTION DOCUMENTS
– PROCESSING INSTRUCTIONS (1)
Shall include:
• Statement of processing location and equipment used
• Method/SOP (or reference to methods) for setting up
equipment e.g cleaning, assembling, calibrating
• Detailed stepwise processing instruction (e.g. Checks on
materials, pre-treatments, sequence for adding materials etc)
• Instructions for any in-process controls with limits
• Requirements for bulk storage of products; include container,
labelling, special storage conditions if applicable
• Any special precautions.
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Chapter 5 - Documentation
PRODUCTION DOCUMENTS
– PROCESSING INSTRUCTIONS (2)
• Shall describe the different operations carried out upon crude
material such as:
– Sorting
– Cleaning
– Drying
– Crushing, and
– Sifting
• Shall include drying time, temperatures, and methods used to
control fragment or particle size
• Shall also describe sieving process/other methods of
removing foreign materials.
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Chapter 5 - Documentation
PRODUCTION DOCUMENTS
– PROCESSING INSTRUCTIONS (3)
• In particular, written instructions and records, shall be
available to ensure that each container of the product is
carefully examined to detect any adulteration/substitution or
presence of foreign matter, such as:
– metal, glass pieces, animal parts or excrement, stones, sand or rot
and signs of decay.
• For product preparation, instructions shall include:
– details of base or solvent
– time and temperatures of extraction,
– details of any concentration stages and
– methods used.
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
PACKAGING INSTRUCTIONS
• Formally authorised Packaging Instructions should be
available for each product pack size and type.
• Shall include:
– Product name
– Description of product dosage form, strength (if applicable)
– Pack size (expressed in terms of number, weight or volume of
product in final container)
– Complete list of all packaging materials required for standard
batch size including quantities, sizes and types with the code or
reference number relating o the specifications of each
packaging material
– An example/ copy of relevant printed packaging materials and
specimens indicating where to apply batch number references,
and shelf life of the product
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Chapter 5 - Documentation
PACKAGING INSTRUCTIONS
• Special precautions to be observed
• Description of packaging operation
• Details of in-process controls with instructions for
sampling and acceptance limits
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Chapter 5 - Documentation
BATCH PROCESSING RECORDS
• Batch Processing Record is that part of Batch Manufacturing
Record
• Should be kept for each batch processed
• Should be based on the relevant parts of the currently
approved Manufacturing Formula and Processing Instructions.
• Method of preparation of such records shall be designed to
avoid transcription errors.
• Record should carry the batch number of the product being
manufactured.
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Chapter 5 - Documentation
BATCH PROCESSING RECORDS
Before any processing begins line clearance should be
done and documented:
– Recorded verification that equipment and work station
clear of previous products, documents or materials not
required for planned process
– Equipment clean and suitable for use
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Chapter 5 - Documentation
BATCH PROCESSING RECORDS
During processing, the following should be recorded at time
action is taken, and after completion, and the record shall be
dated and signed by person responsible for processing
operations:
– Product name
– Dates and times of
 Initiation
 significant intermediate stages and
 Completion of production
– Name of person responsible for each stage of production
– Date and signature of operator of different significant steps of
production and where appropriate, of the person who checked
each of these operations (e.g. weighing, adding active material)
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Chapter 5 - Documentation
BATCH PROCESSING RECORDS
• Batch number and/or analytical control number include
quantities of each starting material actually weighed
• Any relevant processing operation or event and major
equipment used
• A record of in-process controls, date and signature of person
carrying them out and results obtained
• Product yield obtained at different and pertinent stages of
manufacture
• Notes on special problems including details, with signed
authorisation for any deviation from the manufacturing
formula and processing instructions
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ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
BATCH PACKAGING RECORDS
• Is part of Manufacturing Record and should be kept for each
batch or part of batch processed.
• Shall be based on relevant parts of Packaging Instructions
• Method of preparation of such records should be designed to
avoid transcription errors
• Record shall carry Batch Number (BN) and quantity of bulk
product to be packed, as well as BN and planned quantity of
Finished Products (FP) that will be obtained
53
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
BATCH PACKAGING RECORDS
Before any packaging operation begins:
– Recorded checks that equipment and work station clear of
previous products, documents or materials not required
for planned packaging operations
– Equipment clean and suitable for use
54
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
BATCH PACKAGING RECORDS
Information should be entered at time each action is taken, and
after completion, and the record shall be dated and signed by
person(s) responsible for packaging operations:
i. Product name
ii. Dates and times of packaging operation
When there is risk of contamination, packaging
activity should be done within the day itself
iii. Name of responsible persons carrying out packaging
operation
iv. Date and signature of operators of different
significant steps
55
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
BATCH PACKAGING RECORDS
v. Records of verification for identity and conformity with Packaging
Instructions including the results of in-process controls
vi. Details of packaging operations carried out, including references to
equipment and the packaging lines used
vii. Samples of printed packaging materials used, which include the
batch/lot number, expiry date and any additional overprinting
viii. Notes on any special problems or unusual events
ix. Quantities and reference no. or identification of all printed
packaging materials and bulk product issued, used, destroyed or
returned to stock and quantities of obtained product – for
adequate reconciliation
Annex 5 - Sample Batch Manufacturing Record
56
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
• Written procedures and records must be available for
receipt of each delivery of each starting materials and
packaging material.
• Records of receipt should include the following:
– Name of material on delivery note and containers
– In-house name and/or code of material
– Date of receipt, date and signature of receiving staff
– Name of supplier and manufacturer
– Manufacturer’s batch/reference no.
– Total quantity and no. of containers obtained
– Batch Number assigned after receipt
– Any relevant comment (e.g State of containers)
57
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
• SOPs should be available for the following:
– Internal labelling, quarantine and storage of starting
materials, packaging materials and other materials as
appropriate
– Operation of each equipment and placed in close
proximity to instrument or equipment
– Sampling (which specify person authorised to take
samples, sampling tools, and sampling instructions)
58
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
Describe details of batch/lot numbering system
• Objective – ensuring each batch of intermediate, bulk, or Finish
Products is identified with a specific Batch Number
• Batch numbering procedures shall assure that same Batch Number
will not be repeatedly used; this applies also to reprocessing.
• Batch Number allocation should be immediately recorded e.g. in
logbook.
• Record should include date of allocation, product identity and size of
batch.
• SOP for batch numbering that are applied to processing stage and to
respective packaging stage should be related to each other.
59
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
• Quarantine, release and rejection of materials and products,
in particular release for sale of Finish Products by authorised
person.
• Records shall be maintained of distribution of each batch of
product in order to facilitate recall of batch if necessary.
60
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
• SOPs and associated records should be available for
the following:
– equipment assembly;
– operation of analytical apparatus and calibration;
– maintenance, cleaning, and sanitisation of equipment and
premises;
– personnel matters including qualification, GMP training,
clothing, and hygiene;
– environmental monitoring;
– pest control;
61
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
SOPs and associated records should be available for the
following:
– adverse product reactions, complaints and product recalls
– returns and recovered products, rejected
products/materials;
– disposal and destruction of the rejected products/materials;
– self-inspection / quality audit
– change control , handling deviation, Corrective Action
Preventive Action (CAPA)
– product quality review
62
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
STANDARD OPERATING PROCEDURES (SOPS)
& RECORDS
• Logbooks
– Should be kept for major or critical equipment
– Shall record the usage (name of products and batch number) and as
appropriate, any calibrations, maintenance, cleaning, or repair
operations, including dates and the identity of the people who carried
out the operations
– Should be recorded in chronological order (for use of equipment and
areas where product been processed).
• Several of the mentioned procedures, specifications and/or records
may be combined together in one specific document, e.g.:
a) Batch Processing Instruction and Batch Packaging Instruction; and
b) Processing Records and Batch Packaging Records can be merged into
a single document.
63
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
REFERENCES
1. ASEAN Guidelines on Good Manufacturing Practice for
Traditional Medicines.
2. ASEAN Guidelines on Good Manufacturing Practice for
Health Supplements.
3. ASEAN Training Module on Guideline for Cosmetic
GMP(2003) – Chapter on Documentation (2005).
64
ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015
Chapter 5 - Documentation
THANK YOU!
ONE VISION, ONE IDENTITY, ONE COMMUNITY

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ASEAN-TMHS-GMP-Training-–-Chapter-5-Documentation-FD.pdf

  • 1. Prepared by: Approved by: ASEAN TMHS GMP Task Force 30 November 2016 Endorsed by: ASEAN TMHS Product Working Group ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements (TM/HS) CHAPTER 5 - DOCUMENTATION Brunei Darussalam and Lao PDR 1
  • 2. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation ACKNOWLEDGEMENT We would like to thank the following review team for their input to this training module. 2 Muhammad Lukmani Ibrahim Chair of ASEAN GMP TF Quitevis, Ludivina Fama Co-Chair of ASEAN GMP TF Mega Valentine ASEAN Secretariat Hasmilawaty Mohammad Taib Brunei Darussalam Jamilah Metusin Brunei Darussalam Hean Kimseat Cambodia Som Samnang Cambodia Kristiana Haryati Indonesia Widiastuti Adiputra Indonesia Bounleuane Douangdeuane Lao PDR Solivanh Sengchanh Lao PDR Sivong Sengaloundeth Lao PDR Mohd Nasrul Mohamad Noor Malaysia Sharifah Mastura Ahmad Fuad Malaysia Thiri Kyaw Soe Myanmar Wah Wah Aung Myanmar Mary Angeline V. Francisco Philippines Ms. Rochel Averion Francisco Philippines Ong Hai Ann, Terrance Singapore Pinpong Intarapanich Thailand Thida Thaveerit Thailand Lam Quoc Hung Vietnam Luu Duc Du Vietnam Mak Sum Shing, Andrew AAHSA Tamotsu Iwai AAHSA Robles, Frances Evelyn AATMI
  • 3. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation OUTLINE • Objective • Purpose • Principle • General Guidelines • Quality Control Documents • Specifications • Production Documents • Packaging Instructions • Batch Manufacturing Records: – Processing – Packaging • Standard Operating Procedures and Records • An example of Document Format 3
  • 4. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation OBJECTIVE • An essential element of quality assurance is good documentation practices. • The system of documentation devised or adopted should have as its main objective to establish, monitor, and record “quality” for all aspects of the production, quality control and quality assurance. • Record provides evidence of work done. 4
  • 5. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PURPOSE 5 • Clearly written documentation prevents errors that may arise in oral or casually written communication • It provides assurance that quality related activities are carried out exactly the way they have been planned and approved • The achievement of conformity and quality improvement • Purpose of documentation : • To ensure that there are specifications for all materials and methods of manufacture and control • Employees know what to do • Responsibilities and authorities are identified • Ensure that authorized persons have all information necessary for release • Provide audit trail • Forms the basis for improvement.
  • 6. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PRINCIPLE • Good documentation constitutes an essential part of the quality assurance system and should exist for all aspects of GMP. • Clearly written documentation prevents errors from spoken communication and permits tracing of batch history of the product, from purchasing of starting materials to the distribution of finished products. • It shall be able to record executed activities for maintenance, storage, quality control, distribution and other specific matters linked to GMP. • For manufacturing activities, a documentation system must be prepared. • The system consisting of manufacturing formulae and instructions, specifications, procedures and records must be free from errors and clearly established. 6
  • 7. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation GOOD DOCUMENTATION PRACTICE GENERAL GUIDELINES • The system of documentation shall be: – able to record the complete history of each batch. – adequate to permit investigation and tracing of any defective products. • Documents shall contain all necessary information, to be kept up to date and any amendment shall be performed by following proper document change control procedure and authorised. It shall include provision for periodic review and revision as necessary. • Product related records shall be retained for at least one year after the expiry date of the finished product. 7
  • 8. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation GOOD DOCUMENTATION PRACTICE GENERAL GUIDELINES Documents shall: – be designed, prepared and laid out in an orderly fashion – be written in detail and in simple language that can be easily understood by the user – have unambiguous contents – have title, nature and purpose shall be clearly stated – not be hand-written – be regularly reviewed and kept up to date – prevent inadvertent use of superseded documents, when they have been revised – be approved, signed and dated by an authorised person – be distributed with care 8
  • 9. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation Reproduced documents shall: – be clear, legible and duly authorised. – not allow any error during the reproduction of documents Records shall: – be made in clear, legible, and indelible handwriting. Sufficient space shall be provided for such entries. – be signed and dated, and where appropriate the reason of the alteration to be recorded when any alteration made to the entry on a document. The alteration shall permit the reading of the original information. – be made or completed at the time each action is taken and in such a way that all significant activities concerning the manufacture the product are traceable. – be readily available throughout the period of retention. 9 GOOD DOCUMENTATION PRACTICE GENERAL GUIDELINES
  • 10. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation GOOD DOCUMENTATION PRACTICE GENERAL GUIDELINES Electronic Data : Data may be recorded by electronic systems, photographic or other reliable means, but there shall: – be detailed procedure (e.g. SOP) relating to the system in use – be checked and verified for accuracy of the records – be authorised personnel to enter or modify data in the computer – be a record of changes and deletions – be traceability to all raw data – be restricted by passwords or other means for access – be independently checked and verified for the result of entry of critical data – be protection and back-up for all batch records. 10
  • 11. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation GOOD DOCUMENTATION PRACTICE GENERAL GUIDELINES • The manufacturer shall practice what is documented in the written procedures. • Under circumstances where there is a change in the practice, the written procedures shall be promptly updated. • If a written procedure was revised, appropriate training shall be provided to ensure that the personnel carry out the work in accordance to the revised procedure. 11
  • 12. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation TIERS OF DOCUMENTATION 12 Broadly, all documents relating to quality fall in to the following categories:  Quality Manual (optional)  Procedures (QSP and SOP)  Work Instructions (can be merged with Procedures)  Records Legend: QSP - Quality Standard Procedure SOP - Standard Operating Procedure All levels are integrated to form a comprehensive and cohesive documentation network via a system of cross referencing Records Work Instructions Procedures Quality Manual
  • 13. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation TIERS OF DOCUMENTATION 13 QM QSP #03 QSP #02 STANDARD PROCEDURE QSP #01 QUALITY MANUAL (optional) WI #03 WI #02 WORK INSTRUCTION WI #01 WP #03 WP #02 WORK PROTOCOL WP #01 STD #03 STD #02 STANDARD TEST / SPECIFICA-TION STD #01 CE #03 CE #02 CODE ETHICS / WORK POLICY CE #01 IL #03 IL #02 IDENTITY LABELS IL #01
  • 14. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation QUALITY MANUAL (OPTIONAL) 14 The strategic document that outlines the organization’s system of providing quality assurance to achieve customer satisfaction. Objectives :  Describe the quality system structure  Declare the quality policy and organization goal  Describe how the organization meets the quality goal Content of quality manual :  The quality policy declaration  The goal of quality;  The organisational structure including responsibility and authority of each key personnel  Procedures, instructions and resources for implementing the quality management. User :  All personnel in the organization  Another parties, auditors, and customers Records Records Work Instructions Procedures Quality Manual
  • 15. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PROCEDURES 15 The tactical document that outlines the activities or operations of the organisation in implementing the stated quality policies. Objectives : Describe in detail how activities should be done, controlled and recorded in implementing the definite policy Standard Operating Procedures explains:  What the process is and it’s purpose  Where activity is operating  Who is responsible for every activity  When activity is completed, sequential of the activities, frequency, etc.  How activity can be finished follow the work instruction design or other reference documents  Reference to the other relevant documents User :  All personnel who set up and run the processes Records Work Instructions Procedures Quality Manual Procedures
  • 16. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SUPPORTING DOCUMENTS OR WORK INSTRUCTIONS 16 The operational document containing instructions specifying how the activities are performed or products are accepted. Records Procedures Quality Manual Objectives :  It is an instruction document, step by step for guideline to execute the daily activity or operation for personnel in every function  It is used departmentally, every task or every line. Content of work instructions :  Detailed explanation of instructions to finish the job, detailed handling of method, equipment and machine  Related to the technical matters with stressing for operation, inspection & testing. User :  All personnel who operates the certain task Supporting documents:  Worksheet, checklist  Visual (illustration, flow chart, layout plan, photo) Work Instructions
  • 17. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation S.O.P. versus W.I. 17  Process oriented  Describe step of procedure  Supporting the Quality Manual  Explain general description on certain process and give systematic action to ensure product quality  Procedure guideline which involve several departments and/or sections  During implementation need other supported documents  Guideline at organization level QUALITY PROCEDURE/SOP  Task oriented  Describe detail instruction  Operation guidance  Dedicated to explain special task, method, or technique which should be done to achieve target quality  Instruction guidance which dedicated for certain department or section only  During implementation can stand alone  Guidance at operational level WORKING INSTRUCTION SOP and WI can be merged depending on the documentation system adopted by the company
  • 18. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation RECORDS 18 Records, including charts and data pertaining to design, inspection, testing, survey, audit, review or related results, should be maintained as important evidence to demonstrate:  Quality System has been effectively implemented;  that products and services have been developed and delivered appropriately with the requirements. All Records should be :  legible and clear;  Dated;  readily identifiable and retrievable;  carry authorisation status;  retained for a designated period;  protected from damage and deterioration while storage.  All calculations should be duly recorded Work Instructions Quality Procedures Quality Manual Records
  • 19. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation FORMAT OF DOCUMENT 19  No “best format” in documentation system.  Each document should be suitable for all users  In general, all quality documents can be written in the following format :  narrative  flowchart  combination narrative and flowchart  electronic / computerized system
  • 20. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation DOCUMENT NUMBERING SYSTEM 20 Every document shall have a unique number • to facilitate traceability • Yet simple to facilitate saving and controlling of the document
  • 21. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation CONTENT OF DOCUMENT 21 What should be written in the document: • Name of document • Name of company, department or division of the maker • Document number • Revision number • Page and number of pages of document • Date of approved • Effective date • Name and signature of the person who prepared the document • Names and signatures of the person who reviewed and person approved the document • Content of procedure/instruction
  • 22. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation NARRATIVES DOCUMENT 22 • The most common format being used • The narrative document can be described as the following:  Policy reference  Objective : why and for what  Coverage area  Document reference  Responsible person  Detail procedure  Record if needed
  • 23. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation FLOWCHART DOCUMENT 23 Schematic representation which describe the flow of processes in certain target activity Very clear and easy to understand Sample of the flowchart document can be written as beside schema For complicated process, sometimes flowchart alone might not be able to capture detailed information therefore it should be combined with a narrative
  • 24. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation Incoming Packaging Material Quality Control Sampling / Testing Incoming Starting Material Quality Control Sampling / Testing Dispensing Mixing In Process Quality Control Filling In Process Quality Control Packaging / Cartoning Finished Product Quality Control 24 Typical Production Flowchart Rejected Failed Passed Rejected Failed Warehouse Passed Rejected Rejected Passed Passed Failed Failed Rejected Failed Passed
  • 25. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation COMBINED DOCUMENTS 25 Sometimes narrative document and flowchart are also supported by design/lay out Legend 1 = Mixer 2 = Intermediate bin with activated discharge 3 = Feed metering unit 4 = Metal separator 5 = UPZ fine impact mill with pin discs 6 = UPZ fine impact mill with pin discs 7 = Automatic reverse-jet filter 8 = Fan 9 = Rotary valve 10 = End-product bin with activated discharge 11 = Bagging unit 12 = Control cabinet A = Feed product B = Perfume addition C = End product
  • 26. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation DOCUMENT CONTROL 26 As mentioned in the previous slides, documents shall: • Be approved, signed and dated by appropriate authorised persons • Be properly authorized before making any change • Records shall be made or completed each time action is taken in such a way that all significant activities concerning the manufacture of the product are traceable • There shall also be a way to differentiate master hard copy document from all duplicated copies (e.g. stamp “MASTER WHEN RED” on master copy and stamp “CONTROLLED COPY” on distributed copies) • Distributed documents should be recorded (e.g. using distribution list)
  • 27. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation DOCUMENT CONTROL 27 • Obsolete documents: • Control copies shall be retrieved from users based on distribution list and properly destroyed to prevent inadvertent use • Obsolete master documents shall be marked “obsolete” and archived • Create a list/index of all documents established
  • 28. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation DISTRIBUTION OF DOCUMENTS 28 • Only up-to-date documents shall be distributed • Copy of documents should be distributed to relevant parties and available at point of use e.g. Processing and Packaging Instructions should be available in Production Areas whereas Test Methods shall be available in QC labs • Only document Controller or QC/QA are authorised to distribute the document in accordance to written procedure
  • 29. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation REVIEW AND REVISION OF DOCUMENTS 29 • Documents shall be reviewed periodically to confirm that they are up to date. • Changes to the procedures/steps on the document shall go through the proper change control and approved by an authorised person • The newly revised documents shall state: • The date of revision • Reason for the revision • The new effective date
  • 30. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation RECORD KEEPING RULES “Do Not” Rules 30 • DO NOT leave any blanks in forms (shall indicate “nil” or “N/A” when there is no legitimate entry) • DO NOT leave mistakes uncorrected (check your entries) • DO NOT scribble out mistakes (shall not obscure original entries) • DO NOT write correct entries over incorrect entries (writing over shall not obscure original entries) • DO NOT forget to initial and date entry • DO NOT use pencil (all entries should be made using permanent ink)
  • 31. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation LIST OF DOCUMENTS REQUIRED 1. Quality Control Documents 2. Production Documents 3. Standard Operating Procedures (SOPs) and Records 31
  • 32. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation QUALITY CONTROL DOCUMENTS • Must be readily available from Quality Control Dept.: – Specifications: • Natural materials • Starting and packaging materials • Intermediate and bulk products • Finished products (FP) – Sampling Procedures – Testing Procedures and records (incl. analytical worksheets and/or laboratory notebooks) – Analytical reports and/or certificates – Data from environmental monitoring, if appropriate – Procedures for and records of calibration of instruments and maintenance of equipment • Any QC documentation (e.g. test records, data, reports, etc) relating to batch record – retained at least one year after expiry date of Finished products 32
  • 33. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation QUALITY CONTROL DOCUMENTS Specifications: – Describe the required characteristics or composition of a product or material or test, while test procedure is required to evaluate the specific quality attributes – Provide the specific details defining the quality of: • Natural materials • Starting material • Packaging materials, • Intermediate and bulk products • Finished products – All specifications should be approved by authorised personnel (QC/QA manager)
  • 34. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – NATURAL MATERIALS Where appropriate the content shall include for : − Scientific name and if possible with reference to the authors. − Details to the source of the natural material (country or region of origin, cultivation, time of harvesting, collection procedures, possible pesticides used, etc.). − Whole plant/animal or only a part material is used. − When dried plant/animal, drying system shall be specified. − Pictorial demonstration macroscopical and/or microscopical examination − Storage condition and shelf life where applicable Annex 1 – Specification for Foeniculi vulgare Assurance for materials from animal parts origin should be free from undesirable disease (e.g. Transmissible Spongiform Encephalopathy). 34
  • 35. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – NATURAL MATERIALS Testing procedures shall be available if the following tests are conducted (where appropriate): – Identifications tests (incl. active constituents, known markers) – Assay (known therapeutic activity or markers where possible) – Limit tests e.g. Ash value, presence of essential oils, loss on drying – Test for heavy metals and likely contaminants, foreign materials and adulterants – Tests for radioactivity, mycotoxin, fungal and microbial contamination – Tests for residual solvents in extracts or Finished Products (if applicable) – Other tests, as required. Annex 2 – Text Method for Foeniculi vulgare 35
  • 36. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – STARTING MATERIALS & PACKAGING MATERIALS • All Starting and Packaging Materials specifications should consist of the following data, where applicable: – Description of the material Designated name of material & internal code reference Reference, if any, to pharmacopoeia monograph Name of approved suppliers, and if possible, original producer of the products Specimen of printed materials, including colour Microbiological standards, if any; 36
  • 37. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – STARTING MATERIALS & PACKAGING MATERIALS Where appropriate the content shall include for : • directions for sampling and testing or reference to procedures; • qualitative and quantitative requirements with acceptance limits; • storage conditions and precautions; and • the maximum period of storage before re-examination • Assurance for materials from animal parts origin should be free from undesirable disease (e.g. Transmissible Spongiform Encephalopathy). 37 Annex 3 – Specification for Ascorbic Acid Annex 4 – Test Method for Ascorbic Acid
  • 38. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – INTERMEDIATE AND BULK PRODUCTS • Specifications for intermediate and bulk products, − shall be available if purchased or transferred, − or if data obtained from intermediate products are used for the evaluation of the finished product − the specifications shall be similar to specifications for starting materials or for finished products 38
  • 39. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – FINISHED PRODUCTS All specifications of finished products should describe the following: • Designated name of product (and internal code reference where applicable); • Formula or a reference to; • Description of dosage form and package details; • Directions for sampling and testing or reference to procedure where applicable; • Qualitative and quantitative requirements with acceptable limits where applicable; • Storage condition and any special handling precautions, where applicable; • Shelf-life or expiry date. 39
  • 40. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation SPECIFICATIONS – FINISHED PRODUCTS Specifications for finished products (contd.): − Qualitative and quantitative requirements, with the acceptance limits, where applicable:  Physical appearance such as colour, taste, texture, size, etc;  Uniformity of weight (for tablets and capsules), disintegration (for tablets, capsules and pills), hardness and friability (for tablets), and viscosity (for internal and external liquids);  Heavy metals limits;  Microbial limits;  Other tests, as required, such as preservatives 40
  • 41. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation OTHER QUALITY CONTROL DOCUMENTS For other Quality Control Documents (e.g. Sampling Procedures, Testing Procedures and records, Analytical reports and/or certificates) please refer to the details Chapter 7 – Quality Control 41
  • 42. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PRODUCTION DOCUMENTS – Manufacturing Formula and Processing Instructions – Packaging Instructions – Batch Processing Records – Batch Packaging Records 42
  • 43. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PRODUCTION DOCUMENTS – MANUFACTURING FORMULA Formally authorised Manufacturing Formula and Processing Instructions should be available for each product and batch size to be manufactured and often they are combined in one document Shall include: • Product name with reference code relating to its specification • Description of product dosage form and strength, and batch size • List of all starting materials – Amount of each – Designated name and reference which is unique to the material – Substance that may disappear during processing • Statement of expected final yield with acceptance limits. 43
  • 44. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PRODUCTION DOCUMENTS – PROCESSING INSTRUCTIONS (1) Shall include: • Statement of processing location and equipment used • Method/SOP (or reference to methods) for setting up equipment e.g cleaning, assembling, calibrating • Detailed stepwise processing instruction (e.g. Checks on materials, pre-treatments, sequence for adding materials etc) • Instructions for any in-process controls with limits • Requirements for bulk storage of products; include container, labelling, special storage conditions if applicable • Any special precautions. 44
  • 45. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PRODUCTION DOCUMENTS – PROCESSING INSTRUCTIONS (2) • Shall describe the different operations carried out upon crude material such as: – Sorting – Cleaning – Drying – Crushing, and – Sifting • Shall include drying time, temperatures, and methods used to control fragment or particle size • Shall also describe sieving process/other methods of removing foreign materials. 45
  • 46. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PRODUCTION DOCUMENTS – PROCESSING INSTRUCTIONS (3) • In particular, written instructions and records, shall be available to ensure that each container of the product is carefully examined to detect any adulteration/substitution or presence of foreign matter, such as: – metal, glass pieces, animal parts or excrement, stones, sand or rot and signs of decay. • For product preparation, instructions shall include: – details of base or solvent – time and temperatures of extraction, – details of any concentration stages and – methods used. 46
  • 47. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PACKAGING INSTRUCTIONS • Formally authorised Packaging Instructions should be available for each product pack size and type. • Shall include: – Product name – Description of product dosage form, strength (if applicable) – Pack size (expressed in terms of number, weight or volume of product in final container) – Complete list of all packaging materials required for standard batch size including quantities, sizes and types with the code or reference number relating o the specifications of each packaging material – An example/ copy of relevant printed packaging materials and specimens indicating where to apply batch number references, and shelf life of the product 47
  • 48. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation PACKAGING INSTRUCTIONS • Special precautions to be observed • Description of packaging operation • Details of in-process controls with instructions for sampling and acceptance limits 48
  • 49. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PROCESSING RECORDS • Batch Processing Record is that part of Batch Manufacturing Record • Should be kept for each batch processed • Should be based on the relevant parts of the currently approved Manufacturing Formula and Processing Instructions. • Method of preparation of such records shall be designed to avoid transcription errors. • Record should carry the batch number of the product being manufactured. 49
  • 50. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PROCESSING RECORDS Before any processing begins line clearance should be done and documented: – Recorded verification that equipment and work station clear of previous products, documents or materials not required for planned process – Equipment clean and suitable for use 50
  • 51. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PROCESSING RECORDS During processing, the following should be recorded at time action is taken, and after completion, and the record shall be dated and signed by person responsible for processing operations: – Product name – Dates and times of  Initiation  significant intermediate stages and  Completion of production – Name of person responsible for each stage of production – Date and signature of operator of different significant steps of production and where appropriate, of the person who checked each of these operations (e.g. weighing, adding active material) 51
  • 52. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PROCESSING RECORDS • Batch number and/or analytical control number include quantities of each starting material actually weighed • Any relevant processing operation or event and major equipment used • A record of in-process controls, date and signature of person carrying them out and results obtained • Product yield obtained at different and pertinent stages of manufacture • Notes on special problems including details, with signed authorisation for any deviation from the manufacturing formula and processing instructions 52
  • 53. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PACKAGING RECORDS • Is part of Manufacturing Record and should be kept for each batch or part of batch processed. • Shall be based on relevant parts of Packaging Instructions • Method of preparation of such records should be designed to avoid transcription errors • Record shall carry Batch Number (BN) and quantity of bulk product to be packed, as well as BN and planned quantity of Finished Products (FP) that will be obtained 53
  • 54. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PACKAGING RECORDS Before any packaging operation begins: – Recorded checks that equipment and work station clear of previous products, documents or materials not required for planned packaging operations – Equipment clean and suitable for use 54
  • 55. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PACKAGING RECORDS Information should be entered at time each action is taken, and after completion, and the record shall be dated and signed by person(s) responsible for packaging operations: i. Product name ii. Dates and times of packaging operation When there is risk of contamination, packaging activity should be done within the day itself iii. Name of responsible persons carrying out packaging operation iv. Date and signature of operators of different significant steps 55
  • 56. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation BATCH PACKAGING RECORDS v. Records of verification for identity and conformity with Packaging Instructions including the results of in-process controls vi. Details of packaging operations carried out, including references to equipment and the packaging lines used vii. Samples of printed packaging materials used, which include the batch/lot number, expiry date and any additional overprinting viii. Notes on any special problems or unusual events ix. Quantities and reference no. or identification of all printed packaging materials and bulk product issued, used, destroyed or returned to stock and quantities of obtained product – for adequate reconciliation Annex 5 - Sample Batch Manufacturing Record 56
  • 57. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS • Written procedures and records must be available for receipt of each delivery of each starting materials and packaging material. • Records of receipt should include the following: – Name of material on delivery note and containers – In-house name and/or code of material – Date of receipt, date and signature of receiving staff – Name of supplier and manufacturer – Manufacturer’s batch/reference no. – Total quantity and no. of containers obtained – Batch Number assigned after receipt – Any relevant comment (e.g State of containers) 57
  • 58. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS • SOPs should be available for the following: – Internal labelling, quarantine and storage of starting materials, packaging materials and other materials as appropriate – Operation of each equipment and placed in close proximity to instrument or equipment – Sampling (which specify person authorised to take samples, sampling tools, and sampling instructions) 58
  • 59. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS Describe details of batch/lot numbering system • Objective – ensuring each batch of intermediate, bulk, or Finish Products is identified with a specific Batch Number • Batch numbering procedures shall assure that same Batch Number will not be repeatedly used; this applies also to reprocessing. • Batch Number allocation should be immediately recorded e.g. in logbook. • Record should include date of allocation, product identity and size of batch. • SOP for batch numbering that are applied to processing stage and to respective packaging stage should be related to each other. 59
  • 60. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS • Quarantine, release and rejection of materials and products, in particular release for sale of Finish Products by authorised person. • Records shall be maintained of distribution of each batch of product in order to facilitate recall of batch if necessary. 60
  • 61. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS • SOPs and associated records should be available for the following: – equipment assembly; – operation of analytical apparatus and calibration; – maintenance, cleaning, and sanitisation of equipment and premises; – personnel matters including qualification, GMP training, clothing, and hygiene; – environmental monitoring; – pest control; 61
  • 62. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS SOPs and associated records should be available for the following: – adverse product reactions, complaints and product recalls – returns and recovered products, rejected products/materials; – disposal and destruction of the rejected products/materials; – self-inspection / quality audit – change control , handling deviation, Corrective Action Preventive Action (CAPA) – product quality review 62
  • 63. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation STANDARD OPERATING PROCEDURES (SOPS) & RECORDS • Logbooks – Should be kept for major or critical equipment – Shall record the usage (name of products and batch number) and as appropriate, any calibrations, maintenance, cleaning, or repair operations, including dates and the identity of the people who carried out the operations – Should be recorded in chronological order (for use of equipment and areas where product been processed). • Several of the mentioned procedures, specifications and/or records may be combined together in one specific document, e.g.: a) Batch Processing Instruction and Batch Packaging Instruction; and b) Processing Records and Batch Packaging Records can be merged into a single document. 63
  • 64. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation REFERENCES 1. ASEAN Guidelines on Good Manufacturing Practice for Traditional Medicines. 2. ASEAN Guidelines on Good Manufacturing Practice for Health Supplements. 3. ASEAN Training Module on Guideline for Cosmetic GMP(2003) – Chapter on Documentation (2005). 64
  • 65. ASEAN Guidelines on GMP for Traditional Medicines / Health Supplements - 2015 Chapter 5 - Documentation THANK YOU! ONE VISION, ONE IDENTITY, ONE COMMUNITY