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Good Manufacturing
Practices
PRESENTED TO. PROF. ZEENAT IQBAL
BY MD ASAD
M.PHARM 1 SEMESTER (PHARMACEUTICS)
SPER JAMIA HAMDARD
1
CONTENTS
• Introduction
• Building block of GMP
• Why GMP is important?
• Principles of GMP
• Good manufacturing practices for premises and
materials
• Good manufacturing practices for requirements of plant and equipment
• GMP Compliance in a Pharmaceutical Company
• Case study of GMP
• Case study: product recall due to labeling error
• How do GMPs of different countries compare?
• Enforcement of GMP in Different countries
• References
2
ELIXIR SULFANILAMIDE
Sulfanilamide is a drug used to treat
streptococcal infections, and was produced in
powder and tablet form. Because children often
needed to take the drug for sore throats, the
S.E. Massengill Company developed a liquid
form of this drug. They tested it for flavor,
appearance, and fragrance, and found it
acceptable. They soon found out that many
people who took this drug were dying terrible
deaths of kidney failure and experiencing
stoppage of urine, severe abdominal pain,
nausea, vomiting, stupor, and
convulsions. Many of the victims were children.
3
Schedule-M
• Schedule M is a part of Drug and Cosmetic act 1940.
• It is GMP for pharmaceuticals that should be followed by
pharmaceutical manufacturing units in India.
• It is a part of a quality assurance which ensures that the
products are consistently manufactured and controlled to
the Quality standards appropriate to their intended use.
• GMP" - A set of principles and procedures which, when
followed by manufacturers for therapeutic goods, helps
ensure that the products manufactured will have the
required quality
4
DEFINITION
 GMP is that part of Quality Assurance
which ensures that product consistently
produced and controlled to the quality
standard appropriate to their in use and
as required by the marketing
authorization. Good Manufacturing
Practices (GMPs) are regulations that
describe the equipment, facilities, and
controls required for producing:
 Human and veterinary
products
 Medical devices
 Processed food
5
INTRODUCTION
Usually see “cGMP” – where c = current, to
emphasize that the expectations dynamic. It is
designed to minimize the risks involved in any
pharmaceutical product that cannot be eliminated
through testing the final product.
These regulations, which have the force of law,
require that manufacturers processors, and
packagers of drugs, medical devices, some food,
and blood protective steps to ensure that their
products are safe, pure, and effective.
6
7
WHY GMP IS IMPORTANT?
 A poor quality medicine may contain toxic substances that have been
unintentionally added.
 A medicine that contains little or none of the claimed ingredient will
not have the intended therapeutic effect.
 Final testing of the product cannot ensure the Quality efficiency and
safety.
 Final testing may always not detect contamination, error, etc.
8
 Conformance to the predetermined specification.
 To minimize contamination e.g.:- microbial contamination.
 To eliminate error.
 To produce product of consistent quality.
 Government requirement.
 Ensure quality product.
 Reduce rejects, recalls.
 Satisfied customers.
 Company image and reputation.
9
 CODE OF FEDERAL REGULATIONS
(CFR):
 It is the Portion of FDA.
 The collection of final regulations published in the federal
register (daily published records of proposed rules, final
rules, meeting notices, etc.
 Divided into 50 titles.
 Current regulations of GMP appear in part 210 (title 21) of
code of federal regulations published by USFDA.
10
 PRINCIPLES OF GMP:
 Design and construct the facilities and equipment properly
 Follow written procedures and Instructions
 Document work
 Validate work
11
• Monitor facilities and equipment audits.
• Write step by step operating procedures and work on
instructions.
• Design ,develop and demonstrate job competence .
• Protect against contamination .
• Control components and product related processes.
• Conduct planned and periodic audits .
12
 PARTS OF GMP:
13
Part 1
For
Premises
And
Materials
Part 2
Requirement
of plant &
equipment
GMP
PART I
GOOD MANUFACTURING PRACTICES FOR PREMISES
AND
MATERIALS
1. GENERAL REQUIREMENTS
1.1. Location and surroundings
The factory buildings for mfg. of drugs shall
be so situated or shall have such measures
as: -
To avoid risk of contamination from
external environment.
Any factory, which produces obnoxious
odors, fumes, dust, smoke, chemical or
14
1.2. Building and premises
The building should be designed in such a way that permits mfg.
operations in hygienic conditions.
 Compatible with other mfg. operations.
Adequately provided with working space.
To avoid risk of mix-ups.
To avoid contamination.
Designed to avoid entry of pests, birds, rodents etc. Interior
surface should be smooth and free from crakes
The production and dispensing area shall be well lightened,
ventilated, and may have proper air handling system.
Proper drainage system as specified for various categories of
products.
15
1.3. Water system
There shall be validated system for treatment of water to render it
potable.
Potable water should be used to perform all the operations except
cleaning and washing. The storage tanks shall be cleaned
periodically and records maintained by the licensee.
1.4. Disposal of waste
The disposal of sewage and effluents shall be in conformity with
the requirements of Environment Pollution Control Board.
All bio-medical waste shall be destroyed as per the provisions of
Bio-Medical Waste Rules, 1996.
Record shall be maintained.
Provision shall be made for proper storage of waste materials.
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2. Warehousing area
Adequate areas for proper warehousing of various categories of
materials and products.
Designed and adapted to ensure good storage conditions.
Quarantine area shall be clearly demarcated and restricted to
authorized persons.
Separate sampling area for active raw materials and excipients.
17
18
3. Production area
Designed to allow the production preferably in uni-flow and with
logical sequence of operations.
Separate mfg. facilities shall be provided for the mfg. of
contamination causing and potent products such as;
•β-lactam, sex hormones and cyto-toxic substance.
•Service lines shall be Well designed and constructed, shall be
identified by colours. Direction of flow shall be marked.
4. Ancillary areas
Rest and refreshment rooms shall be separate from other areas.
Facility for changing, storing clothes and for washing and toilet purpose
shall be easily accessible and adequate.
Areas for housing animals shall be isolated and maintained as
prescribed in rule 150- C (3) of D & C Rules, 1945.
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5. Quality control area
Quality control laboratories shall be independent of the
production areas seprates areas shall be provided each for
physico-chemical, biological, micro-biological or radio –isotope
analysis.
Adequate space shall be provided to avoid mix-ups and cross
contamination.
The design of the laboratory shall take into account the suitability
of construction materials and ventilation.
Separate air handling units and radioisotopes testing areas. The
laboratory shall be provided with regular supply of water of
appropriate quality for cleaning and testing purposes.
20
6. Personnel
 The manufacture and testing shall be conducted under direct supervision of qualified
technical staff.
 Personnel for QA & QC shall be qualified and experienced.
 No. of personnel employed shall be adequate and in direct proportion to the workload.
 Personnel in production and QC lab. shall receive training appropriate to the duties &
responsibility assigned to them.
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7. Health, clothing and sanitation of
workers
The personnel handling beta- lactum antibiotics
shall be tested for penicillin sensitivity before
employment and those handling sex hormones,
cytotoxic substances and other potent drugs shall
be periodically examined for adverse effect.
Prior to employment, all personnel shall undergo
medical examination including eye examination,
and shall be free from tuberculosis, skin and other
communicable or contagious diseases.
22
• Clothing:
Protection of operator and product,
highly potent products or those of
particular risk.
Need for special protective clothing.
Personnel should not move between
areas producing different products.
Garments need to be cleaned.
23
8. Manufacturing operations &
controls
All manufacturing operations shall be
performed by trained personnel under direct
supervision of approved technical staff
approved by the licensing Authority. All the
materials & containers used in mfg. process
shall be conspicuously labeled with
• Name of product
• Batch number and batch size
• Stages of manufacture
24
Products not prepared under aseptic condition are
required to be free from pathogens like,
Salmonella, Escherichia coli, Pyocyanea, etc.
The licensee shall prevent mix-up and cross-
contaminations of drug materials and drug product
by proper air –handling system, pressure
differential, segregation, and status labeling and
cleaning. Proper records and SOPs thereof shall
be maintained.
25
9. Sanitation in manufacturing
premises
Manufacturing premises shall be
Cleaned and maintained according
to validated cleaning procedures.
Manufacturing areas shall not be
use as storage or thoroughfare.
A Routine sanitation program shall
be drawn up and observed.
Area shall be Well lightened
production area particularly where
visual on line controls carried out.
26
10. Raw materials
The licensee Keep an inventory of all raw materials to be used at any stage of
production of drugs and maintain records as per Schedule U.
All materials shall store under appropriate storage condition & follow ‘first
in/first expiry’–‘first out’ rule.
Raw material from each batch checked for quality & appropriately labels the
storage area.
27
Only raw materials which have been released by the
quality control department and which are within their
shelf- life shall be used .It shall be ensured that shelf
life of formulation product shall not exceed with that of
active raw material used.
It shall be ensured that all the containers of
raw materials are placed on the raised
platforms/racks and not placed directly on the floor.
28
11. EQUIPMENTS
 Equipment shall be located, designed, constructed, adapted and maintained to suit the
operations to be carried out.
 The layout and design of the equipment shall aim to minimize the risk of errors and permit
effective cleaning and maintenance in order to avoid cross- contamination, build –up of
dust or dirt and in general any adverse effect on the quality of product.
 Balance and other measuring equipment of an appropriate range, accuracy and precision
shall be available.
29
12. Documentation and records
 It is the essential part of the Quality assurance system. as
such , shall be related to all aspect of GMP.
 Its aim is to define the specification for all materials, method of
mfg. and control, to ensure that all personnel concerned with
manufacture know the information necessary to decide
whether or not to release a batch of a drug for sale and to
provide an audit trail that shall permit investigation of the
history of any suspected defective batch.
 Documents shall be approved, signed and dated by
appropriate and authorized persons.
30
13. Labels and other printed materials
Necessary for identification of the drugs and their
use.
Printed in bright colours and legible manner.
All containers and equipment shall bear appropriate
labels.
Different color coded labels can be used.
Printed packaging materials & leaflets shall be
stored separately to avoid mix-up.
Packaging, labeling and release shall be done after
approval of QC department
Record of receipt and use of all material shall be
maintained.
31
14. Quality assurance
To understand key issues in quality assurance/quality control.
To understand specific requirements on organization, procedures,
processes and resources.
To develop actions to resolve current problems.
• Principles of Quality Assurance Wide-ranging concept:
Covers all matters that individually or collectively
Influence the quality of a product. It is the totality of the arrangements
made with the object of ensuring that the products are of the quality
required for the intended use.
Quality Assurance incorporates GMP and also product design and
development.
32
Requirements for QA Systems
Ensure products are developed correctly.
Identify managerial responsibilities.
Provide SOPs for production and control.
Organize supply and use of correct starting materials.
Define controls for all stages of manufacture and packaging.
Ensure finished product correctly processed and checked before
release
Ensure products are released after review by authorized person
Provide storage and distribution
Organize self-inspection
33
15. Self-inspection and Quality audit
It may be useful to constitute a self-inspection team supplemented with a
quality audit procedure for assessment of all or part of a system with the
specific purpose of improving it.
Ensures that a company‟s operations remain compliant with GMP.
Assists in ensuring continuous quality improvement.
• Must recommend corrective action if shortcomings are observed and
set a timetable for corrective action to be completed.
34
Written instructions for self-inspection
include:
Personnel
Premises including personnel facilities
Maintenance of buildings and equipment
Storage of starting materials and finished
Products
Equipment
Production and in-process controls
35
16. QUALITY CONTROL SYSTEM
Quality control shall be concerned with sampling,
specification, testing, documentation, and release
procedures.
It is not confined to laboratory operations but shall be
involved in all decisions concerning the quality of the
product.
The department as a whole shall have other duties such as
to establish, evaluate, validate and implement all Quality
control procedure and methods.
All the batches released after certification of QC department.
36
Maintain reference/retained sample from each
batch.
The area of the quality control laboratory may be
divided into chemical, instrumentation
,microbiological and biological testing.
Adequate area having the required storage
conditions shall be provided for keeping
references samples. The quality control
department shall evaluate, maintain and storage
reference samples
37
17. Specifications
For raw material & packaging material.
For product containers & closures.
For in-process & bulk products.
For finished product.
For preparation of containers &
closures.
38
18. Master formula records: -
Related to –
All mfg. procedures for each product.
Batch size to be manufactured.
39
19. Packaging records:-
There shall be Authorized packaging instructions for each product, pack size & type that
include;
 Name of product with other description.
 Volume of product in final container.
 Complete list of all the packaging materials with.
 Quantities size & type.
 Description of packaging operations.
 Detail of in process control
40
20. Batch packaging record: -
A batch packaging record shall be kept for each batch
or part batch processed. It shall be based on the
relevant parts of packaging instructions, and the method
of preparation of such records shall be designed to
avoid transcription error.
Before any packaging operation begins, checks be
made and recorded that the equipments and the work
stations are clear of the previous products, documents
or materials not required for the planned packaging
operations, and that the equipment is clean and suitable
for use.
41
21.BATCH PROCESSING RECORDS:-
There shall be Batch processing Record for each product. It shall be based on the parts of
the currently approved master formula.
Before any processing begins, check shall be performed and recorded to ensure that the
equipment and work station are clear of previous products, documents or materials not required
for the planned process are removed and that equip0ment is clean an suitable for use.
During processing, the following information shall be recorded at the time each action is taken and
the record shall be dated and signed by the person responsible for the processing operations:
 Name po0f the product
 No. of the batch being manufactured
 Date and time of commencement
 Initials of the operator of the different significant steps of production and where appropriate, of
the person who checked each of these operations.
 Batch no.
 Equipment used.
 Records of the IPQC.
 Amount of then product obtained at different and critical stages of manufacture.
 Special problems.
42
22.Standard operating procedures (SOP), and
Records ,Regarding.
22.1 Receipt of material
Includes –
 Written SOP for receipt of raw, primary & printed packaging materials.
 Written SOP for the internal labelling, quarantine & storage of various materials.
 SOPs for related instrument & equipment
43
22.2. Sampling
Includes –
SOP for method of sampling.
SOP for equipment to be used.
Precautions to avoid contamination.
Instruction for qty. & pooling of sample.
Specific precautions for sampling of sterile or
hazardous materials
44
22.3. Batch numbering
SOPs
Describing the detail of batch numbering set up for each batch of
intermediate, bulk or finished product.
Applied to a processing stage & to the respective packaging
stage.
Include date of allocation, product identity & batch size.
22.4 Testing: -
There shall be written procedures for testing materials and products
at different stages of manufacture, describing the methods and
equipment to b e used, the tests performed shall be recorded.
45
23. Validation and Process validation: -
Essential part of GMP and shall be conducted as per
the pre–defined protocols.
A written report summarizing recorded result and
conclusions shall be prepared, documented and
maintained.
Shall be undergo periodic validation to ensure that they
remain capable of achieving the intended results.
When any new master formula or method of
preparation is adopted, steps shall be taken to
demonstrate its suitability for routine processing.
46
24.PRODUCT RECALLS: -
 A prompt and effective recall system of defective products shall be devised for timely
information of all concerned stockists, wholesalers, suppliers, up to the retail level
within the shortest period. The licensee may make use of both print and electronic
media in this regard.
 The distribution records shall be readily made available to the persons designated
fore recalls.
 The effectiveness of the arrangements for recalls shall be evaluated from time to time.
 The recalled products shall be storded separately in a secured segregated area
pending final decision on them.
25. COMPLAINTS AND ADVERSE REACTIONS: -.
 All complaints thereof concerning product quality shall be carefully reviewed and
recorded according to written procedures. Each complaint shall be investigated
/evaluated by the designated personnel of the company and records of investigation
and remedial action taken thereof shall be maintained.
 Reports of serious adverse drug reactions resulting from the use of a drug along with
comments and documents shall be forthwith reported to the concerned Licensing
Authority.
47
26. SITE MASTER FILE:-
The licensee shall prepare a succinct document in the form, of
„Site Master File „
Containing specific and factual GMP about th production and/or
control of pharmaceutical manufacturing preparations carried out at
the licensed premises. It shall contain the following
General information
Personnel
Premises
Equipment
Sanitation
Documentation
Production
48
 Quality control: -
o Description of the quality system and of the activities of t he quality
control department. Procedure for the release of the finished
products.
 Loan licence manufacture and licensee:-
o Description of the way in which compliance of GMP by the loan
licensee shall be assessed.
 Distribution, complaints and product recall
 Self-inspection
 Export of drugs: - it may be
o Products exported to different countries.
o Complaints and product recall, if any.
49
DIFFERENT SUBPARTS OF PART I
PART IA: Specific requirements for manufacture of sterile products, parenteral
preparations (small volume injectables and large volume parenteral) and sterile
ophthalmic preparations.
PART I B: Specific requirements for manufacture of oral solid dosage forms
(Tablets and capsules)
PART IC: Specific requirements for manufacture of oral liquids (syrups, elixirs,
emulsion, suspension)
PART ID: Specific requirements for manufacture of topical products i.e. external
preparation (creams. Ointments, pastes, emulsions, lotions, solutions, dusting
powders and identical products.
PART IE: Specific requirements for manufacture of metered dose inhalers (MDI).
PART IF: Specific requirements of premises, plant and materials for manufacture
of active pharmaceutical ingredients (BULK DRUGS).
50
PART- 2
Requirements of plant and equipment
51
Area requirements Basic installation Ancillary Area
1. External preparations 30 sq. m 10 sq. m
2. Oral liquid preparation 30. sq. m 10 sq. m
3. Tablets 80 sq. m 20 sq. m
Coating section 30 sq. m 10 sq. m
4. Powders 30 sq. m -
5. Capsules 25 sq. m 10 sq. s
6. Surgical dressings 30 sq. m -
7. Ophthalmic preparation
8. Pessaries & suppositories
25 sq. m
20 sq. m
10 sq. m
-
9. Inhalers & vitrellae 20 sq. m -
10. Repacking of drug &
pharmaceutics chemicals
30 sq. m -
11. Parenteral preparation
52
COMMON PROBLEMS IN GMP EXECUTION:
1.Organization
 Lack of commitment
 ack of resources for execution
2. Layout & Construction
 No quarantine area
 Insufficient environmental monitoring
 Cracked floor
3. Equipment:
 No calibration
 No performance check of balance before use
 Rusty
 Parts not kept improperly
53
4. Laboratory Testing:
 Poor reference standard keeping
 Poor data recording
 Reagent with no label
5. Documentation & Recording:
 No signature; no countercheck
 Improper correction made
 No written procedure
 Incomplete complaint record
 No up-to-date training record
 No document review
54
6. Labelling:
Status not defined clearly
Poor labelling control
Release label not kept securely
Inadequate reconciliation of batch label
Defective equipment with no label
7. Validation:
Insufficient validation
Insufficient raw data
No validation programme
55
GMP Compliance in a Pharmaceutical Company
56
How to Sustain GMP Compliance in Your
Pharmaceutical Company
The pharmaceutical industry in every country is heavily regulated by
central and state authorities. They have developed GMP compliance
regulations to enhance the safety of pharmaceutical products and to
ensure that patients get only the highest quality of medicines.
Being compliant with GMP regulations is good for your
company as well. It drastically reduces the number of batch recalls and
decreases the number of adverse reactions reported in patients from
different geographical localities. Not to forget, both these facts have
direct impact on your reputation.
57
Set up a Quality Team
Having a team of skilled workers focused on improving
quality and complying with GMP is the building block of
your mission to manufacture quality products. Pick up
one efficient member from every department including
manufacturing, testing, storage and distribution to build
a team with diverse experience and knowledge. The
members should thoroughly analyse and discuss the
problems occurring in routine operations.
58
Quality Assessment
When the team identifies root cause of any
problem, they can decide whether it has the
potential to deter the GMP compliance. Their
views and results are used as inputs to develop
appropriate improvement measures.
59
Validation Activities
 Many employees in pharmaceutical companies still don’t clearly
know what validation really is. Well, it’s just a documented act of
demonstrating that the instruments, processes and activities used in
your firm regularly lead to expected results without any hindrance.
Since GMP requires a number of things to be validated, make it an
ongoing process focusing on the following aspects: -
 Process validation
 Cleaning and sanitation validation
 Computer system validation
 Analytical method validation
60
Surprise Audits
An unexpected audit of every department gives you
fair idea about what’s going on in the facility and the
level of GMP compliance. It helps you identify the
real sources of non-compliance. Take appropriate
measures to curb the situation before it
deteriorate. Share the findings and solutions with
employees in all the departments. Invite them to
send their feedback along with new ideas to
improve compliance.
61
Monitor the Performance
Schedule the monitoring of instruments,
equipments, processes and staff skills at specific
intervals to achieve greater efficiency. Sometimes
the employees in production department may be
ignoring a problem with an equipment just
because it has become a common incident.
62
Compliance Training
Perhaps the best way to ensure GMP compliance is to provide your staff
compliance training, educate them and let them realise the importance of
Good Manufacturing Practice. It’s an effective way for pharmaceutical
manufacturers, medical device companies and food product firms to
ensure the safety and effectiveness of their products. The employees at
work should have received prior training on record-keeping, sanitation,
equipment handling, labelling, constant vigilance, Standard Operating
Procedures, ways to minimize errors, etc.
Without compliance, all the guidelines, manuals, instructions and principles
are worthless. What’s the use of all those rules if you aren’t following
them? That won’t yield desired outcomes. So, GMP compliance is an
important part of any pharmaceutical firm and its reputation.
63
Case study of GMP
The end of 2010 saw Johnson and Johnson (J&J) faced with a set of
quality related problems with product deficiencies surfacing in a range of
drugs manufactured by one of its units, McNeil Consumer Healthcare
(MNCH) in the United States (US). J&J, which had adopted a crisis
management approach that is still considered the Gold Standard in Brand
Crisis Management following the Tylenol Crisis in 1982, was caught on the
wrong foot this time around. The company came in for strong criticism for
its failure to respond promptly when a range of products meant for adults,
children and infants were reported to be sub-standard. It was alleged that
there were continued lapses in J&J's quality control despite repeated
complaints from consumers and the Food and Drug Administrator (FDA),
the industry regulator.
A Matter of Trust: Johnson & Johnson Product Recalls
64
Issues:
This case is most suitable for the courses on Brand
Management, Brand Crisis Management, Supply
Chain Crisis Management, Quality Control,
Corporate Social Responsibility (CSR), Marketing,
Strategy, and Business Ethics. It can also be used
to explain in some part the significance of the
Corporate Governance System and Organizational
Structure and Control.
65
The Crisis
Based on the FDA's reports alleging lapses and
misconduct at J&J, the matter was taken up by the
House Committee on Oversight and Government
Reform (HCOGR) of the US Congress. FDA testified
that MNCH had quality problems with one of its
products which J&J had discovered in 2008 itself. It
further stated that the company had reported the
problem to FDA only after a significant delay in
2009...
66
The "Phantom Recall"
Product recalls were not a new phenomenon either in the
pharmaceutical industry or in J&J. In fact, J&J had an
exemplary track record in managing such crises in the past
which had built consumer confidence in the company,
making it an enviable brand. But this time around, it was the
nature of the initial recalls, the delay in the formal recalls, the
prolonged series of recalls, and the FDA finding multiple
lapses in the manufacturing and quality control processes
which brought to the issue a significantly high level of
attention from society, the regulator, as the well as the
governing and supervisory bodies...
67
J&J Crisis (1982): The Gold Standard in Brand
Crisis Management
This was not the first time that J&J had faced a major
product quality related crisis. A major Tylenol tragedy had
occurred in 1982 as well. In September 1982 , seven
people died in the Chicago area after reportedly ingesting
Tylenol pain relief capsules. Investigations found that the
medicine had been laced with potassium cyanide. In an
immediate response, J&J recalled all of the estimated 31
million bottles of Tylenol products that were in circulation,
on October 5, 1982...
68
J&J Crisis (2010): Crisis in Brand Crisis
Management
The troubled waters at J&J had started to become evident much
in 2008 when J&J the company found that some batches of its
painkiller Motrin were not dissolving in water as they were
supposed to. The company halted distribution of Motrin and
told the FDA that it would conduct random checks of retailers'
shelves to confirm if the problem required a product recall...
69
A Matter of Trust
Pharmaceutical companies' superior quality which brings
the life critical customer confidence to products has been
their major success factor. It was on this major count that
J&J was alleged to have failed. For the many customers
who had been paying premium prices for J&J products
throughout their lives and had depended on this long
trusted brand to deliver health products and medicines
they could use with complete confidence, it meant a loss
of confidence in the company...
70
CASE STUDY: PRODUCT RECALL DUE TO
LABELING ERROR
Endo Pharmaceuticals Inc, is voluntarily recalling two lots of Robaxin
(methocarbamol tablets, USP) 750mg tablets 100 count bottle pack
to the consumer level. The products have been found to have
incorrect daily dosing information on the label due to a labelling
error which misstates the daily dose as "two to four tablets four
times daily" rather than the correct dosage of "two tablets three
times daily."
71
Patients who follow the directions on the bottle may experience
significant drowsiness or dizziness which would put them at
risk of falls or an overdose which could result in seizures,
coma, or death. To Robaxin 750mg Tablets contain the active
ingredient methocarbamol and are indicated as an adjunct
therapy to rest, physical therapy and other measures for the
relief of discomfort associated with acute, painful
musculoskeletal conditions. Robaxin 750mg Tablets are packed
in bottles of 100 tablets with package labeling featuring the
product name, strength, lot number, expiry date and the
National Drug Code number NDC 52244-449-10.
72
The recall includes the following product
lots:
Robaxin 750mg, 100 Count Bottle pack, Lot 216702P1,
Expiration Date: September 2020; and Robaxin 750mg, 100
Count Bottle pack, Lot 220409P1, Expiration Date: January
2021.
Endo Pharmaceuticals Inc. is notifying distributors and retailers
in writing through Inmar, Inc. Inmar is arranging for return of
all
73
Recalled products.
Distributors and retailers that have product which is being
recalled should stop distributing and dispensing and return to
the place of purchase.
This Product Recall is being made with the knowledge of the
United States Food and Drug Administration (FDA).
74
How do GMPs of different countries compare?
 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
 The World Health Organization (WHO) version of GMP is used by pharmaceutical
regulators and the pharmaceutical industry in over one hundred countries worldwide,
primarily in the developing world.
 The European Union's GMP (EU-GMP) enforces more compliance requirements than
the WHO GMP, as does the Food and Drug Administration's version in the US.
 Similar GMPs are used in other countries, with Australia, Canada, Japan, Singapore
and others having highly developed/sophisticated GMP requirements.
 In the United Kingdom, the Medicines Act (1968) covers most aspects of GMP in what
is commonly referred to as "The Orange Guide", because of the color of its cover, is
officially known as The Rules and Guidance for Pharmaceutical Manufacturers and
Distributors
75
Enforcement of GMP in Different countries
GMPs are enforced in the United States by the FDA;
Within the European Union, GMP inspections are performed by
National Regulatory Agencies (e.g., GMP inspections are
performed in the United Kingdom by the Medicines and
Healthcare products Regulatory Agency (MHRA);
In Australia by the Therapeutical Goods Administration (TGA);
In India and Pakistan by the Ministry of Health
76
Refrences……
 (PDF) Good manufacturing Practice (researchgate.net)
 The Theory and practice of industrial pharmacy by Lachman. Pg:- 804
 www.bioscreen.com.
 Good manufacturing practices for pharmaceutical. A plan for total quality control,
second edition by Sidney H. Willig
 GMP Compliance in a Pharmaceutical Company (gmp7.com)
 www.fda.com
 Microsoft Word - BA_Good Manufacturing Practices (GMPs).docx
 A Matter of Trust: Johnson & Johnson Product Recalls|Business Strategy|Case
Study|Case Studies (icmrindia.org)
 Case Study: Product Recall due to labeling error • NCK Pharma
77
THANK YOU
78

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Good Manufacturing Practices 34.pptx

  • 1. Good Manufacturing Practices PRESENTED TO. PROF. ZEENAT IQBAL BY MD ASAD M.PHARM 1 SEMESTER (PHARMACEUTICS) SPER JAMIA HAMDARD 1
  • 2. CONTENTS • Introduction • Building block of GMP • Why GMP is important? • Principles of GMP • Good manufacturing practices for premises and materials • Good manufacturing practices for requirements of plant and equipment • GMP Compliance in a Pharmaceutical Company • Case study of GMP • Case study: product recall due to labeling error • How do GMPs of different countries compare? • Enforcement of GMP in Different countries • References 2
  • 3. ELIXIR SULFANILAMIDE Sulfanilamide is a drug used to treat streptococcal infections, and was produced in powder and tablet form. Because children often needed to take the drug for sore throats, the S.E. Massengill Company developed a liquid form of this drug. They tested it for flavor, appearance, and fragrance, and found it acceptable. They soon found out that many people who took this drug were dying terrible deaths of kidney failure and experiencing stoppage of urine, severe abdominal pain, nausea, vomiting, stupor, and convulsions. Many of the victims were children. 3
  • 4. Schedule-M • Schedule M is a part of Drug and Cosmetic act 1940. • It is GMP for pharmaceuticals that should be followed by pharmaceutical manufacturing units in India. • It is a part of a quality assurance which ensures that the products are consistently manufactured and controlled to the Quality standards appropriate to their intended use. • GMP" - A set of principles and procedures which, when followed by manufacturers for therapeutic goods, helps ensure that the products manufactured will have the required quality 4
  • 5. DEFINITION  GMP is that part of Quality Assurance which ensures that product consistently produced and controlled to the quality standard appropriate to their in use and as required by the marketing authorization. Good Manufacturing Practices (GMPs) are regulations that describe the equipment, facilities, and controls required for producing:  Human and veterinary products  Medical devices  Processed food 5
  • 6. INTRODUCTION Usually see “cGMP” – where c = current, to emphasize that the expectations dynamic. It is designed to minimize the risks involved in any pharmaceutical product that cannot be eliminated through testing the final product. These regulations, which have the force of law, require that manufacturers processors, and packagers of drugs, medical devices, some food, and blood protective steps to ensure that their products are safe, pure, and effective. 6
  • 7. 7
  • 8. WHY GMP IS IMPORTANT?  A poor quality medicine may contain toxic substances that have been unintentionally added.  A medicine that contains little or none of the claimed ingredient will not have the intended therapeutic effect.  Final testing of the product cannot ensure the Quality efficiency and safety.  Final testing may always not detect contamination, error, etc. 8
  • 9.  Conformance to the predetermined specification.  To minimize contamination e.g.:- microbial contamination.  To eliminate error.  To produce product of consistent quality.  Government requirement.  Ensure quality product.  Reduce rejects, recalls.  Satisfied customers.  Company image and reputation. 9
  • 10.  CODE OF FEDERAL REGULATIONS (CFR):  It is the Portion of FDA.  The collection of final regulations published in the federal register (daily published records of proposed rules, final rules, meeting notices, etc.  Divided into 50 titles.  Current regulations of GMP appear in part 210 (title 21) of code of federal regulations published by USFDA. 10
  • 11.  PRINCIPLES OF GMP:  Design and construct the facilities and equipment properly  Follow written procedures and Instructions  Document work  Validate work 11
  • 12. • Monitor facilities and equipment audits. • Write step by step operating procedures and work on instructions. • Design ,develop and demonstrate job competence . • Protect against contamination . • Control components and product related processes. • Conduct planned and periodic audits . 12
  • 13.  PARTS OF GMP: 13 Part 1 For Premises And Materials Part 2 Requirement of plant & equipment GMP
  • 14. PART I GOOD MANUFACTURING PRACTICES FOR PREMISES AND MATERIALS 1. GENERAL REQUIREMENTS 1.1. Location and surroundings The factory buildings for mfg. of drugs shall be so situated or shall have such measures as: - To avoid risk of contamination from external environment. Any factory, which produces obnoxious odors, fumes, dust, smoke, chemical or 14
  • 15. 1.2. Building and premises The building should be designed in such a way that permits mfg. operations in hygienic conditions.  Compatible with other mfg. operations. Adequately provided with working space. To avoid risk of mix-ups. To avoid contamination. Designed to avoid entry of pests, birds, rodents etc. Interior surface should be smooth and free from crakes The production and dispensing area shall be well lightened, ventilated, and may have proper air handling system. Proper drainage system as specified for various categories of products. 15
  • 16. 1.3. Water system There shall be validated system for treatment of water to render it potable. Potable water should be used to perform all the operations except cleaning and washing. The storage tanks shall be cleaned periodically and records maintained by the licensee. 1.4. Disposal of waste The disposal of sewage and effluents shall be in conformity with the requirements of Environment Pollution Control Board. All bio-medical waste shall be destroyed as per the provisions of Bio-Medical Waste Rules, 1996. Record shall be maintained. Provision shall be made for proper storage of waste materials. 16
  • 17. 2. Warehousing area Adequate areas for proper warehousing of various categories of materials and products. Designed and adapted to ensure good storage conditions. Quarantine area shall be clearly demarcated and restricted to authorized persons. Separate sampling area for active raw materials and excipients. 17
  • 18. 18 3. Production area Designed to allow the production preferably in uni-flow and with logical sequence of operations. Separate mfg. facilities shall be provided for the mfg. of contamination causing and potent products such as; •β-lactam, sex hormones and cyto-toxic substance. •Service lines shall be Well designed and constructed, shall be identified by colours. Direction of flow shall be marked.
  • 19. 4. Ancillary areas Rest and refreshment rooms shall be separate from other areas. Facility for changing, storing clothes and for washing and toilet purpose shall be easily accessible and adequate. Areas for housing animals shall be isolated and maintained as prescribed in rule 150- C (3) of D & C Rules, 1945. 19
  • 20. 5. Quality control area Quality control laboratories shall be independent of the production areas seprates areas shall be provided each for physico-chemical, biological, micro-biological or radio –isotope analysis. Adequate space shall be provided to avoid mix-ups and cross contamination. The design of the laboratory shall take into account the suitability of construction materials and ventilation. Separate air handling units and radioisotopes testing areas. The laboratory shall be provided with regular supply of water of appropriate quality for cleaning and testing purposes. 20
  • 21. 6. Personnel  The manufacture and testing shall be conducted under direct supervision of qualified technical staff.  Personnel for QA & QC shall be qualified and experienced.  No. of personnel employed shall be adequate and in direct proportion to the workload.  Personnel in production and QC lab. shall receive training appropriate to the duties & responsibility assigned to them. 21
  • 22. 7. Health, clothing and sanitation of workers The personnel handling beta- lactum antibiotics shall be tested for penicillin sensitivity before employment and those handling sex hormones, cytotoxic substances and other potent drugs shall be periodically examined for adverse effect. Prior to employment, all personnel shall undergo medical examination including eye examination, and shall be free from tuberculosis, skin and other communicable or contagious diseases. 22
  • 23. • Clothing: Protection of operator and product, highly potent products or those of particular risk. Need for special protective clothing. Personnel should not move between areas producing different products. Garments need to be cleaned. 23
  • 24. 8. Manufacturing operations & controls All manufacturing operations shall be performed by trained personnel under direct supervision of approved technical staff approved by the licensing Authority. All the materials & containers used in mfg. process shall be conspicuously labeled with • Name of product • Batch number and batch size • Stages of manufacture 24
  • 25. Products not prepared under aseptic condition are required to be free from pathogens like, Salmonella, Escherichia coli, Pyocyanea, etc. The licensee shall prevent mix-up and cross- contaminations of drug materials and drug product by proper air –handling system, pressure differential, segregation, and status labeling and cleaning. Proper records and SOPs thereof shall be maintained. 25
  • 26. 9. Sanitation in manufacturing premises Manufacturing premises shall be Cleaned and maintained according to validated cleaning procedures. Manufacturing areas shall not be use as storage or thoroughfare. A Routine sanitation program shall be drawn up and observed. Area shall be Well lightened production area particularly where visual on line controls carried out. 26
  • 27. 10. Raw materials The licensee Keep an inventory of all raw materials to be used at any stage of production of drugs and maintain records as per Schedule U. All materials shall store under appropriate storage condition & follow ‘first in/first expiry’–‘first out’ rule. Raw material from each batch checked for quality & appropriately labels the storage area. 27
  • 28. Only raw materials which have been released by the quality control department and which are within their shelf- life shall be used .It shall be ensured that shelf life of formulation product shall not exceed with that of active raw material used. It shall be ensured that all the containers of raw materials are placed on the raised platforms/racks and not placed directly on the floor. 28
  • 29. 11. EQUIPMENTS  Equipment shall be located, designed, constructed, adapted and maintained to suit the operations to be carried out.  The layout and design of the equipment shall aim to minimize the risk of errors and permit effective cleaning and maintenance in order to avoid cross- contamination, build –up of dust or dirt and in general any adverse effect on the quality of product.  Balance and other measuring equipment of an appropriate range, accuracy and precision shall be available. 29
  • 30. 12. Documentation and records  It is the essential part of the Quality assurance system. as such , shall be related to all aspect of GMP.  Its aim is to define the specification for all materials, method of mfg. and control, to ensure that all personnel concerned with manufacture know the information necessary to decide whether or not to release a batch of a drug for sale and to provide an audit trail that shall permit investigation of the history of any suspected defective batch.  Documents shall be approved, signed and dated by appropriate and authorized persons. 30
  • 31. 13. Labels and other printed materials Necessary for identification of the drugs and their use. Printed in bright colours and legible manner. All containers and equipment shall bear appropriate labels. Different color coded labels can be used. Printed packaging materials & leaflets shall be stored separately to avoid mix-up. Packaging, labeling and release shall be done after approval of QC department Record of receipt and use of all material shall be maintained. 31
  • 32. 14. Quality assurance To understand key issues in quality assurance/quality control. To understand specific requirements on organization, procedures, processes and resources. To develop actions to resolve current problems. • Principles of Quality Assurance Wide-ranging concept: Covers all matters that individually or collectively Influence the quality of a product. It is the totality of the arrangements made with the object of ensuring that the products are of the quality required for the intended use. Quality Assurance incorporates GMP and also product design and development. 32
  • 33. Requirements for QA Systems Ensure products are developed correctly. Identify managerial responsibilities. Provide SOPs for production and control. Organize supply and use of correct starting materials. Define controls for all stages of manufacture and packaging. Ensure finished product correctly processed and checked before release Ensure products are released after review by authorized person Provide storage and distribution Organize self-inspection 33
  • 34. 15. Self-inspection and Quality audit It may be useful to constitute a self-inspection team supplemented with a quality audit procedure for assessment of all or part of a system with the specific purpose of improving it. Ensures that a company‟s operations remain compliant with GMP. Assists in ensuring continuous quality improvement. • Must recommend corrective action if shortcomings are observed and set a timetable for corrective action to be completed. 34
  • 35. Written instructions for self-inspection include: Personnel Premises including personnel facilities Maintenance of buildings and equipment Storage of starting materials and finished Products Equipment Production and in-process controls 35
  • 36. 16. QUALITY CONTROL SYSTEM Quality control shall be concerned with sampling, specification, testing, documentation, and release procedures. It is not confined to laboratory operations but shall be involved in all decisions concerning the quality of the product. The department as a whole shall have other duties such as to establish, evaluate, validate and implement all Quality control procedure and methods. All the batches released after certification of QC department. 36
  • 37. Maintain reference/retained sample from each batch. The area of the quality control laboratory may be divided into chemical, instrumentation ,microbiological and biological testing. Adequate area having the required storage conditions shall be provided for keeping references samples. The quality control department shall evaluate, maintain and storage reference samples 37
  • 38. 17. Specifications For raw material & packaging material. For product containers & closures. For in-process & bulk products. For finished product. For preparation of containers & closures. 38
  • 39. 18. Master formula records: - Related to – All mfg. procedures for each product. Batch size to be manufactured. 39
  • 40. 19. Packaging records:- There shall be Authorized packaging instructions for each product, pack size & type that include;  Name of product with other description.  Volume of product in final container.  Complete list of all the packaging materials with.  Quantities size & type.  Description of packaging operations.  Detail of in process control 40
  • 41. 20. Batch packaging record: - A batch packaging record shall be kept for each batch or part batch processed. It shall be based on the relevant parts of packaging instructions, and the method of preparation of such records shall be designed to avoid transcription error. Before any packaging operation begins, checks be made and recorded that the equipments and the work stations are clear of the previous products, documents or materials not required for the planned packaging operations, and that the equipment is clean and suitable for use. 41
  • 42. 21.BATCH PROCESSING RECORDS:- There shall be Batch processing Record for each product. It shall be based on the parts of the currently approved master formula. Before any processing begins, check shall be performed and recorded to ensure that the equipment and work station are clear of previous products, documents or materials not required for the planned process are removed and that equip0ment is clean an suitable for use. During processing, the following information shall be recorded at the time each action is taken and the record shall be dated and signed by the person responsible for the processing operations:  Name po0f the product  No. of the batch being manufactured  Date and time of commencement  Initials of the operator of the different significant steps of production and where appropriate, of the person who checked each of these operations.  Batch no.  Equipment used.  Records of the IPQC.  Amount of then product obtained at different and critical stages of manufacture.  Special problems. 42
  • 43. 22.Standard operating procedures (SOP), and Records ,Regarding. 22.1 Receipt of material Includes –  Written SOP for receipt of raw, primary & printed packaging materials.  Written SOP for the internal labelling, quarantine & storage of various materials.  SOPs for related instrument & equipment 43
  • 44. 22.2. Sampling Includes – SOP for method of sampling. SOP for equipment to be used. Precautions to avoid contamination. Instruction for qty. & pooling of sample. Specific precautions for sampling of sterile or hazardous materials 44
  • 45. 22.3. Batch numbering SOPs Describing the detail of batch numbering set up for each batch of intermediate, bulk or finished product. Applied to a processing stage & to the respective packaging stage. Include date of allocation, product identity & batch size. 22.4 Testing: - There shall be written procedures for testing materials and products at different stages of manufacture, describing the methods and equipment to b e used, the tests performed shall be recorded. 45
  • 46. 23. Validation and Process validation: - Essential part of GMP and shall be conducted as per the pre–defined protocols. A written report summarizing recorded result and conclusions shall be prepared, documented and maintained. Shall be undergo periodic validation to ensure that they remain capable of achieving the intended results. When any new master formula or method of preparation is adopted, steps shall be taken to demonstrate its suitability for routine processing. 46
  • 47. 24.PRODUCT RECALLS: -  A prompt and effective recall system of defective products shall be devised for timely information of all concerned stockists, wholesalers, suppliers, up to the retail level within the shortest period. The licensee may make use of both print and electronic media in this regard.  The distribution records shall be readily made available to the persons designated fore recalls.  The effectiveness of the arrangements for recalls shall be evaluated from time to time.  The recalled products shall be storded separately in a secured segregated area pending final decision on them. 25. COMPLAINTS AND ADVERSE REACTIONS: -.  All complaints thereof concerning product quality shall be carefully reviewed and recorded according to written procedures. Each complaint shall be investigated /evaluated by the designated personnel of the company and records of investigation and remedial action taken thereof shall be maintained.  Reports of serious adverse drug reactions resulting from the use of a drug along with comments and documents shall be forthwith reported to the concerned Licensing Authority. 47
  • 48. 26. SITE MASTER FILE:- The licensee shall prepare a succinct document in the form, of „Site Master File „ Containing specific and factual GMP about th production and/or control of pharmaceutical manufacturing preparations carried out at the licensed premises. It shall contain the following General information Personnel Premises Equipment Sanitation Documentation Production 48
  • 49.  Quality control: - o Description of the quality system and of the activities of t he quality control department. Procedure for the release of the finished products.  Loan licence manufacture and licensee:- o Description of the way in which compliance of GMP by the loan licensee shall be assessed.  Distribution, complaints and product recall  Self-inspection  Export of drugs: - it may be o Products exported to different countries. o Complaints and product recall, if any. 49
  • 50. DIFFERENT SUBPARTS OF PART I PART IA: Specific requirements for manufacture of sterile products, parenteral preparations (small volume injectables and large volume parenteral) and sterile ophthalmic preparations. PART I B: Specific requirements for manufacture of oral solid dosage forms (Tablets and capsules) PART IC: Specific requirements for manufacture of oral liquids (syrups, elixirs, emulsion, suspension) PART ID: Specific requirements for manufacture of topical products i.e. external preparation (creams. Ointments, pastes, emulsions, lotions, solutions, dusting powders and identical products. PART IE: Specific requirements for manufacture of metered dose inhalers (MDI). PART IF: Specific requirements of premises, plant and materials for manufacture of active pharmaceutical ingredients (BULK DRUGS). 50
  • 51. PART- 2 Requirements of plant and equipment 51 Area requirements Basic installation Ancillary Area 1. External preparations 30 sq. m 10 sq. m 2. Oral liquid preparation 30. sq. m 10 sq. m 3. Tablets 80 sq. m 20 sq. m Coating section 30 sq. m 10 sq. m 4. Powders 30 sq. m -
  • 52. 5. Capsules 25 sq. m 10 sq. s 6. Surgical dressings 30 sq. m - 7. Ophthalmic preparation 8. Pessaries & suppositories 25 sq. m 20 sq. m 10 sq. m - 9. Inhalers & vitrellae 20 sq. m - 10. Repacking of drug & pharmaceutics chemicals 30 sq. m - 11. Parenteral preparation 52
  • 53. COMMON PROBLEMS IN GMP EXECUTION: 1.Organization  Lack of commitment  ack of resources for execution 2. Layout & Construction  No quarantine area  Insufficient environmental monitoring  Cracked floor 3. Equipment:  No calibration  No performance check of balance before use  Rusty  Parts not kept improperly 53
  • 54. 4. Laboratory Testing:  Poor reference standard keeping  Poor data recording  Reagent with no label 5. Documentation & Recording:  No signature; no countercheck  Improper correction made  No written procedure  Incomplete complaint record  No up-to-date training record  No document review 54
  • 55. 6. Labelling: Status not defined clearly Poor labelling control Release label not kept securely Inadequate reconciliation of batch label Defective equipment with no label 7. Validation: Insufficient validation Insufficient raw data No validation programme 55
  • 56. GMP Compliance in a Pharmaceutical Company 56
  • 57. How to Sustain GMP Compliance in Your Pharmaceutical Company The pharmaceutical industry in every country is heavily regulated by central and state authorities. They have developed GMP compliance regulations to enhance the safety of pharmaceutical products and to ensure that patients get only the highest quality of medicines. Being compliant with GMP regulations is good for your company as well. It drastically reduces the number of batch recalls and decreases the number of adverse reactions reported in patients from different geographical localities. Not to forget, both these facts have direct impact on your reputation. 57
  • 58. Set up a Quality Team Having a team of skilled workers focused on improving quality and complying with GMP is the building block of your mission to manufacture quality products. Pick up one efficient member from every department including manufacturing, testing, storage and distribution to build a team with diverse experience and knowledge. The members should thoroughly analyse and discuss the problems occurring in routine operations. 58
  • 59. Quality Assessment When the team identifies root cause of any problem, they can decide whether it has the potential to deter the GMP compliance. Their views and results are used as inputs to develop appropriate improvement measures. 59
  • 60. Validation Activities  Many employees in pharmaceutical companies still don’t clearly know what validation really is. Well, it’s just a documented act of demonstrating that the instruments, processes and activities used in your firm regularly lead to expected results without any hindrance. Since GMP requires a number of things to be validated, make it an ongoing process focusing on the following aspects: -  Process validation  Cleaning and sanitation validation  Computer system validation  Analytical method validation 60
  • 61. Surprise Audits An unexpected audit of every department gives you fair idea about what’s going on in the facility and the level of GMP compliance. It helps you identify the real sources of non-compliance. Take appropriate measures to curb the situation before it deteriorate. Share the findings and solutions with employees in all the departments. Invite them to send their feedback along with new ideas to improve compliance. 61
  • 62. Monitor the Performance Schedule the monitoring of instruments, equipments, processes and staff skills at specific intervals to achieve greater efficiency. Sometimes the employees in production department may be ignoring a problem with an equipment just because it has become a common incident. 62
  • 63. Compliance Training Perhaps the best way to ensure GMP compliance is to provide your staff compliance training, educate them and let them realise the importance of Good Manufacturing Practice. It’s an effective way for pharmaceutical manufacturers, medical device companies and food product firms to ensure the safety and effectiveness of their products. The employees at work should have received prior training on record-keeping, sanitation, equipment handling, labelling, constant vigilance, Standard Operating Procedures, ways to minimize errors, etc. Without compliance, all the guidelines, manuals, instructions and principles are worthless. What’s the use of all those rules if you aren’t following them? That won’t yield desired outcomes. So, GMP compliance is an important part of any pharmaceutical firm and its reputation. 63
  • 64. Case study of GMP The end of 2010 saw Johnson and Johnson (J&J) faced with a set of quality related problems with product deficiencies surfacing in a range of drugs manufactured by one of its units, McNeil Consumer Healthcare (MNCH) in the United States (US). J&J, which had adopted a crisis management approach that is still considered the Gold Standard in Brand Crisis Management following the Tylenol Crisis in 1982, was caught on the wrong foot this time around. The company came in for strong criticism for its failure to respond promptly when a range of products meant for adults, children and infants were reported to be sub-standard. It was alleged that there were continued lapses in J&J's quality control despite repeated complaints from consumers and the Food and Drug Administrator (FDA), the industry regulator. A Matter of Trust: Johnson & Johnson Product Recalls 64
  • 65. Issues: This case is most suitable for the courses on Brand Management, Brand Crisis Management, Supply Chain Crisis Management, Quality Control, Corporate Social Responsibility (CSR), Marketing, Strategy, and Business Ethics. It can also be used to explain in some part the significance of the Corporate Governance System and Organizational Structure and Control. 65
  • 66. The Crisis Based on the FDA's reports alleging lapses and misconduct at J&J, the matter was taken up by the House Committee on Oversight and Government Reform (HCOGR) of the US Congress. FDA testified that MNCH had quality problems with one of its products which J&J had discovered in 2008 itself. It further stated that the company had reported the problem to FDA only after a significant delay in 2009... 66
  • 67. The "Phantom Recall" Product recalls were not a new phenomenon either in the pharmaceutical industry or in J&J. In fact, J&J had an exemplary track record in managing such crises in the past which had built consumer confidence in the company, making it an enviable brand. But this time around, it was the nature of the initial recalls, the delay in the formal recalls, the prolonged series of recalls, and the FDA finding multiple lapses in the manufacturing and quality control processes which brought to the issue a significantly high level of attention from society, the regulator, as the well as the governing and supervisory bodies... 67
  • 68. J&J Crisis (1982): The Gold Standard in Brand Crisis Management This was not the first time that J&J had faced a major product quality related crisis. A major Tylenol tragedy had occurred in 1982 as well. In September 1982 , seven people died in the Chicago area after reportedly ingesting Tylenol pain relief capsules. Investigations found that the medicine had been laced with potassium cyanide. In an immediate response, J&J recalled all of the estimated 31 million bottles of Tylenol products that were in circulation, on October 5, 1982... 68
  • 69. J&J Crisis (2010): Crisis in Brand Crisis Management The troubled waters at J&J had started to become evident much in 2008 when J&J the company found that some batches of its painkiller Motrin were not dissolving in water as they were supposed to. The company halted distribution of Motrin and told the FDA that it would conduct random checks of retailers' shelves to confirm if the problem required a product recall... 69
  • 70. A Matter of Trust Pharmaceutical companies' superior quality which brings the life critical customer confidence to products has been their major success factor. It was on this major count that J&J was alleged to have failed. For the many customers who had been paying premium prices for J&J products throughout their lives and had depended on this long trusted brand to deliver health products and medicines they could use with complete confidence, it meant a loss of confidence in the company... 70
  • 71. CASE STUDY: PRODUCT RECALL DUE TO LABELING ERROR Endo Pharmaceuticals Inc, is voluntarily recalling two lots of Robaxin (methocarbamol tablets, USP) 750mg tablets 100 count bottle pack to the consumer level. The products have been found to have incorrect daily dosing information on the label due to a labelling error which misstates the daily dose as "two to four tablets four times daily" rather than the correct dosage of "two tablets three times daily." 71
  • 72. Patients who follow the directions on the bottle may experience significant drowsiness or dizziness which would put them at risk of falls or an overdose which could result in seizures, coma, or death. To Robaxin 750mg Tablets contain the active ingredient methocarbamol and are indicated as an adjunct therapy to rest, physical therapy and other measures for the relief of discomfort associated with acute, painful musculoskeletal conditions. Robaxin 750mg Tablets are packed in bottles of 100 tablets with package labeling featuring the product name, strength, lot number, expiry date and the National Drug Code number NDC 52244-449-10. 72
  • 73. The recall includes the following product lots: Robaxin 750mg, 100 Count Bottle pack, Lot 216702P1, Expiration Date: September 2020; and Robaxin 750mg, 100 Count Bottle pack, Lot 220409P1, Expiration Date: January 2021. Endo Pharmaceuticals Inc. is notifying distributors and retailers in writing through Inmar, Inc. Inmar is arranging for return of all 73
  • 74. Recalled products. Distributors and retailers that have product which is being recalled should stop distributing and dispensing and return to the place of purchase. This Product Recall is being made with the knowledge of the United States Food and Drug Administration (FDA). 74
  • 75. How do GMPs of different countries compare?  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  The World Health Organization (WHO) version of GMP is used by pharmaceutical regulators and the pharmaceutical industry in over one hundred countries worldwide, primarily in the developing world.  The European Union's GMP (EU-GMP) enforces more compliance requirements than the WHO GMP, as does the Food and Drug Administration's version in the US.  Similar GMPs are used in other countries, with Australia, Canada, Japan, Singapore and others having highly developed/sophisticated GMP requirements.  In the United Kingdom, the Medicines Act (1968) covers most aspects of GMP in what is commonly referred to as "The Orange Guide", because of the color of its cover, is officially known as The Rules and Guidance for Pharmaceutical Manufacturers and Distributors 75
  • 76. Enforcement of GMP in Different countries GMPs are enforced in the United States by the FDA; Within the European Union, GMP inspections are performed by National Regulatory Agencies (e.g., GMP inspections are performed in the United Kingdom by the Medicines and Healthcare products Regulatory Agency (MHRA); In Australia by the Therapeutical Goods Administration (TGA); In India and Pakistan by the Ministry of Health 76
  • 77. Refrences……  (PDF) Good manufacturing Practice (researchgate.net)  The Theory and practice of industrial pharmacy by Lachman. Pg:- 804  www.bioscreen.com.  Good manufacturing practices for pharmaceutical. A plan for total quality control, second edition by Sidney H. Willig  GMP Compliance in a Pharmaceutical Company (gmp7.com)  www.fda.com  Microsoft Word - BA_Good Manufacturing Practices (GMPs).docx  A Matter of Trust: Johnson & Johnson Product Recalls|Business Strategy|Case Study|Case Studies (icmrindia.org)  Case Study: Product Recall due to labeling error • NCK Pharma 77