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HANDLING OF
PRODUCT
COMPLAINT
Nazmi Liana Azmi
INTRODUCTION
3
NATIONAL PHARMACEUTICAL
REGULATORY AGENCY
CENTRE FOR POST
REGISTRATION OF PRODUCTS &
COSMETIC CONTROL
PHARMACOVIGILANCE
SECTION
COMPLAINT
MANAGEMENT SECTION
SURVEILLANCE
SECTION
COSMETIC SECTION
POST MARKET
SURVEILLANCE
5
REGISTRATION CRITERIA
1. POST MARKET QUALITY SURVEILLACE
✘ Market sampling
✘ Laboratory analysis
✘ Label and packaging compliance
6
ACTIVITIES
2. INVESTIGATION OF PRODUCT COMPLAINTS
✘ Quality defects
✘ Regulatory compliance related issues
✘ Safety & efficacy issues
7
ACTIVITIES
3. SAFETY MONITORING OF PRODUCTS
✘ ADR monitoring
✘ Signal detection & risk assessment
✘ Risk communication
✘ Risk Management & research
8
ACTIVITIES
9
Monitor safety profile
REGULATORY ACTIONS
GOALS
Follow up on CAPAs to
improve product quality
Remove unsafe products
from the market in
timely manner
Ensure products are of
quality
HANDLING OF
PRODUCT
COMPLAINTS
11
12
Important!
Can add in
attachment
State the quantity
involved based on
receiving (DO)
Fill up
ADR form
✘ Effective tools of conducting surveillance
✘ Mainly related to quality defects
✘ When necessary, the Marketing Authorisation
Holder required to initiate RCA and propose
CAPA
13
HANDLING OF PRODUCT COMPLAINTS
CLASSIFICATION
OF QUALITY
DEFECTS
✘ An attribute of a product or component which
may affect the QUALITY, SAFETY AND / OR
EFFICACY of the product, and / or which is NOT
IN LINE WITH THE APPROVED MARKETING
AUTHORISATION for the product
15
DEFINITION
16
IN A NUTSHELL..
✘ Wrong product (label & content are different)
✘ Correct product but wrong strength, with serious
medical consequences
✘ Microbial, physical / chemical contamination,
with serious medical consequences
✘ Mix up products within a pack
✘ Serious ADR which are batch / product related
17
CRITICAL QUALITY DEFECTS
(life threatening / serious health risk)
18
Label on the box was
Ternolol 50 but label
on the blister was
Ternolol Tab 100mg
After investigation..
✘ Mislabelling (wrong , missing text / figures)
✘ Missing / incorrect information on package insert
✘ Microbial, physical / chemical contamination, with
medical consequences
✘ Non-compliance with specification (assay, stability, fill /
weight)
✘ Insecure closure with serious medical consequences
(cytotoxics, child-resistant containers, potent product)19
MAJOR QUALITY DEFECTS
(cause illness or mistreatment but not to a
life threatening extent)
20
It was discovered that one of
the constituents of the drug
referred to as an IMPURITY
WAS OUT OF RANGE
Instead of having a chemical
presence of 0.1 per cent, it stood
at 0.3 per cent, due to false
packaging.
✘ Faulty packaging (wrong, missing batch number /
expiry date)
✘ Faulty closure
✘ Tablet defect/ empty blister
✘ Microbial, physical / chemical contamination which is
unlikely to have medical consequences (a strand of hair
embed in a tablet in an intact blister)
21
MINOR QUALITY DEFECTS
(are not likely to pose a significant hazard to
health)
22
Tablet defects – empty
blister / broken tablet
23
What is the
classification of
this defect?
24
Can we do a product complaint
on similar packaging?
STATISTICS
26
27
28
CONCLUSION
- It is the responsibility of
ALL -
30
THANK YOU FOR YOUR
ATTENTION!
Any questions?
Contact me at:
nazmiliana@moh.gov.my
0179224977

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Handling of product complaint

  • 3. 3 NATIONAL PHARMACEUTICAL REGULATORY AGENCY CENTRE FOR POST REGISTRATION OF PRODUCTS & COSMETIC CONTROL PHARMACOVIGILANCE SECTION COMPLAINT MANAGEMENT SECTION SURVEILLANCE SECTION COSMETIC SECTION
  • 6. 1. POST MARKET QUALITY SURVEILLACE ✘ Market sampling ✘ Laboratory analysis ✘ Label and packaging compliance 6 ACTIVITIES
  • 7. 2. INVESTIGATION OF PRODUCT COMPLAINTS ✘ Quality defects ✘ Regulatory compliance related issues ✘ Safety & efficacy issues 7 ACTIVITIES
  • 8. 3. SAFETY MONITORING OF PRODUCTS ✘ ADR monitoring ✘ Signal detection & risk assessment ✘ Risk communication ✘ Risk Management & research 8 ACTIVITIES
  • 9. 9 Monitor safety profile REGULATORY ACTIONS GOALS Follow up on CAPAs to improve product quality Remove unsafe products from the market in timely manner Ensure products are of quality
  • 11. 11
  • 12. 12 Important! Can add in attachment State the quantity involved based on receiving (DO) Fill up ADR form
  • 13. ✘ Effective tools of conducting surveillance ✘ Mainly related to quality defects ✘ When necessary, the Marketing Authorisation Holder required to initiate RCA and propose CAPA 13 HANDLING OF PRODUCT COMPLAINTS
  • 15. ✘ An attribute of a product or component which may affect the QUALITY, SAFETY AND / OR EFFICACY of the product, and / or which is NOT IN LINE WITH THE APPROVED MARKETING AUTHORISATION for the product 15 DEFINITION
  • 17. ✘ Wrong product (label & content are different) ✘ Correct product but wrong strength, with serious medical consequences ✘ Microbial, physical / chemical contamination, with serious medical consequences ✘ Mix up products within a pack ✘ Serious ADR which are batch / product related 17 CRITICAL QUALITY DEFECTS (life threatening / serious health risk)
  • 18. 18 Label on the box was Ternolol 50 but label on the blister was Ternolol Tab 100mg After investigation..
  • 19. ✘ Mislabelling (wrong , missing text / figures) ✘ Missing / incorrect information on package insert ✘ Microbial, physical / chemical contamination, with medical consequences ✘ Non-compliance with specification (assay, stability, fill / weight) ✘ Insecure closure with serious medical consequences (cytotoxics, child-resistant containers, potent product)19 MAJOR QUALITY DEFECTS (cause illness or mistreatment but not to a life threatening extent)
  • 20. 20 It was discovered that one of the constituents of the drug referred to as an IMPURITY WAS OUT OF RANGE Instead of having a chemical presence of 0.1 per cent, it stood at 0.3 per cent, due to false packaging.
  • 21. ✘ Faulty packaging (wrong, missing batch number / expiry date) ✘ Faulty closure ✘ Tablet defect/ empty blister ✘ Microbial, physical / chemical contamination which is unlikely to have medical consequences (a strand of hair embed in a tablet in an intact blister) 21 MINOR QUALITY DEFECTS (are not likely to pose a significant hazard to health)
  • 22. 22 Tablet defects – empty blister / broken tablet
  • 23. 23 What is the classification of this defect?
  • 24. 24 Can we do a product complaint on similar packaging?
  • 26. 26
  • 27. 27
  • 28. 28
  • 29. CONCLUSION - It is the responsibility of ALL -
  • 30. 30 THANK YOU FOR YOUR ATTENTION! Any questions? Contact me at: nazmiliana@moh.gov.my 0179224977