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Sampling
,
Identification and
Testing
(S.I.T.)
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Introduction
Define basic principles for applying sampling,identification and testing requirements
1) Systems and procedures ensuring that samples are representative of the batch when
sampled
Correctly identified
Tested
2) Systems and Procedures in accordance withregulatory and Safety requirements
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Scope
Applies to all manufacturing sites
Applies to all sub-contractors
Applies to all Affiliates
Applies to Raw-materials, isolatedintermediates, APIs, excipients, medicaldevices, packaging materials, inprocessmaterials, bulk and packaged drug products
Does not apply to environmental samples andReference and Retention samples
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Reference Documents
ICH Q7 : Good Manufacturing Practice for ActivePharmaceutical Ingredients
EU GMP Part I Chapter 6 : Quality Control
EU GMP Annex 8 : Sampling of Starting and PackagingMaterials
US CFR : Subpart E-Control of Components and Drug ProductContainers and Closures : 211.80 : General requirements ;
211.84 Testing and approval or rejection of components,drug product containers, and closures ; 211.110 Samplingand testing of in-process materials and drug products,Subpart G-Packaging and Labelling Control : 211.122Materials examination and usage criteria
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Sampling General
Requirements (1)
Composite sample : justify the number of individual samples
Sampling operations recorded with specific items. Records availablefor evaluation as condition of batch release
Additional sampling may be considered in case of OOS/OOT -Based on approved re-sampling protocol
Sterile materials sampled aseptically in environmental zone A.
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Sampling General
Requirements (2)
Sampling personnel initially trained andretrained on regular basis
Only qualified and authorised personnelcan sample
Any anomaly/irregularity during samplinghas to be notified and recorded.
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Sampling GeneralRequirements (3)
Sampling areas designed to protect product fromenvironment and cross contamination and protectpersonnel from the product
Appropriate areas in case of high potency, sensitizingmaterial, antibiotic, etc
Gowning instructions and personnel protective
equipment must be available
Material Safety Data Sheet (MSDS) available beforesampling.
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Sampling GeneralRequirements (4)
Sampling equipment and tools : specified, stored appropriately
protected from contamination, cleaned after use and cleaning
validation performed
Cleanliness status of equipment identifiable
Containers carefully opened and closed
Containers marked when sample taken
Identification of person who performs sampling
Date of sampling recorded.
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Sampling GeneralRequirements (5)
Containers in which samples areplaced must be clean and clearly
labelled
Sampled samples must not be
returned to the batch
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Identification General
Requirements
Identification method : described in thecurrent locally applicable Pharmacopoeia(e.g. USP, EP, JP) or approved Regulatory
File
For material identification, a NIR validated
method can be applied even if notregistered in the Regulatory File; forcountries where the practice is allowed.
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Sampling and Identification
Operations (1) Samples must be representative of the batch of
materials or products from which they are taken
Pre-samples allowed only from approved or
certified suppliers with written agreement onsampling delegation
Place(s) where samples need to be taken oridentification : detailed in SOP
Samplingmust not be the cause of contaminationor cross-contamination
Cleaning operation in case of outer dirty container.
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Sampling and Identification
Operations (3)
Each batch of incoming material forAPI product : subject for identity,
except in case of risk for health andsafety
Such kind of materials to be listedCoA obtained from supplier for each
batch.
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Sampling and Identification
Operations (4)
Sampling plans or procedures minimuminformation
Version, approvers name, date of approvalName of material, amount to be sampled
Sample packaging and labelling, storageconditions
Sampling equipment, safety/handlingprecautions : sterile, noxious product,pyrogens.
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Sampling and Identification
Operations (5)
Sampling plans or procedures minimuminformation (cont.)
Number of containers to be sampled
Number of samples to be taken
Sampling/Identification location within thecontainer :
Supplier pre-samples or identification locationwhen direct NIR identification
Measurement units : quantity (g, ml, mg,)
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Sampling and IdentificationOperations (6)
Sampling plans or procedures minimuminformation (cont.)
Composite sample (number of sample for a
composite)
Sub-division of sample
Department/person - the sample is to be sent
Instructions for cleaning and storage ofsampling equipment.
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Sampling and IdentificationSpecific Rules (1)
Materials used for Manufacture of APIs:StartingMaterials, RawMaterialsandSynthesisIntermediates
Manufacturers of SM, RM, SImust be identified
If Manufacturer is certified, reduced testing isallowed
Reduced testing on hold in case of investigationand return to reduced testing only if supported byconclusion of investigation and approval fromQuality operations.
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Sampling and IdentificationSpecific Rules (2)
Materials used for Manufacture of APIs (cont.) Starting Materials, Raw Materials
1) Manufacturer within ICH Region*:A justified sampling and identification plan
based on criteria such as : Criticality of material Material variability Supplier past quality history Manufacturing factory dedication Certification of Supplier
At least one test for Identity of each batch
(except in case of health and safety risk sample eachcontainer)
* ICH = European Union, North America, Japan + EFTA:Switzerland, Norway, Iceland and Liechtenstein.
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Sampling and IdentificationSpecific Rules (3)
Materials used for Manufacture of APIs (cont.)
Starting Materials, Raw Materials
2) Manufacturer outside ICH Region:Sampling of each container, identification on composite
sample and full testing(Identification on each container not required, in case of deviation/OOT:
investigation to be performed and concluded).
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Sampling and IdentificationSpecific Rules (4)
Materials used for Manufacture of APIs(cont.)Intermediates Synthesisexternal manufacturer
3) Regardless of geographical origin:Sampling on each container to make a
composite sample For identification
For full testing
(Identification on each container not required, in case of deviation/OOT :
investigation to be performed and concluded).
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Sampling and IdentificationSpecific Rules (5)
APIs and ExcipientsAPI produced within company: sampling and
identification limited to one container (process
validation demonstrates homogeneity,container integrity)
API not produced within company and
excipients with origin outside the ICH region Identification of material on each container
Composite sample for later full testing.
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Sampling and IdentificationSpecific Rules (6)
APIs and ExcipientsAPI not produced at company manufacturing
site and excipients with origin from the ICH
Region: sampling and identification dependupon following parameters: Supplier nature and status : when supplier is
certified
Supplier quality assurance system
Manufacturing and control conditions
Nature of API, excipient and drug product in whichthey are used.
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Sampling and IdentificationSpecific Rules (7)
APIs and Excipients (cont.)
API or excipient coming from single product manufactureror plant
API, excipient coming directly from manufacturer in sealedcontainers and manufacturer regularly audited
In such case : Sampling and Identification performedon a reduced number of containers according to
justified sampling plan
If previous conditions not fulfilled : identification oneach container
APIs and Excipients used for Parenterals : EACHcontainer must be identified.
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Sampling and IdentificationSpecific Rules (8)
Packaging MaterialsSampling plan based on quantity received and
required, nature and criticality of material(geographical origin, primary packaging, printed
packaging), production methods, qualityassurance of manufacturerSampling place/location is dependant on supplier
status :Approved or certified supplier > sampling possible by
supplier : written sampling delegation and justifiedsampling plan are mandatory Supplier with no quality agreement > sampling by
own company manufacturing site : justified samplingplan.
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Sampling and IdentificationSpecific Rules (9)
Intermediates for Drug Product, Bulk DrugProducts, In-Process Materials and Drug Products Intermediates and Bulk drug product produced by
same company and received at another site : sampling and identification limited to one container (due to
homogeneity demonstrated by process validation and by transportvalidation)
Each container perfectly sealed at receipt
Intermediates and Bulk drug product not produced by
same company: Sampling depending upon parameters : criticality of product,manufacturing in a dedicated facility, quality of sealing, experiencewith sub-contractor
Each individual container sampled and tested for identity.
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Sampling and IdentificationSpecific Rules (10)
Intermediates for Drug Product, Bulk DrugProducts, In-Process Materials and DrugProducts (cont.)Intermediates and Bulk drug product not
produced by same company: Tests other than identity, sampling can be reduced or
performed on each container, based on justified samplingplan
In-Process Materials and Drug Products : If relevant, sampling and identification performed according
to marketing autorisation requirements or site samplingplan.
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Testing OperationsRequirements (1)
Control operations of received goods - for eachcontainer check/perform and document
Container status and cleanliness
Correct storage conditions
Damages, closures integrity, potential tempering,homogeneity of containers
Labelling in comparison with delivery documentation
Number of containers
Materials reconciliation and weight discrepancies
1 lot per pallet.
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Testing OperationsRequirements (2)
Analytical Methods validated
Results obtained recorded and checked, calculation critically examined
Tests performed must be recorded with following data:
Material name, dosage form Batch number, Manufacturer/Supplier if appropriate
References of specifications and testing procedures Results, calculations, Suppliers CoA Testing date(s) Initials of personnel who performed testing and verification Release or rejection decision and signature of manager Tests records and raw data archived
All IPC must be performed and recorded with QC approval
Raw materials tested in accordance with written procedures and specifications inrespect with current pharmacopeias and/or approved dossiers.
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Testing OperationsRequirements (3)
Packaging Materialsmost frequent defects and degree of criticality listed
Tests reduced
if certified supplier raw materials, intermediates, synthesis intermediates
and drug products manufactured within companyregardless of origin
Reduced testing not allowed raw materials used in manufacture of parenterals products
raw materials, intermediates, synthesis intermediates anddrug products with origin outside ICH region.
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Testing OperationsRequirements (4)
GLYCEROL and Diethyleneglycol testing sites are required to:
Evaluate traceability of manufacturers/distributors
Define manufacturers location : ICH or not ICH
Declare manufacturers status certified or not certified
Evaluate the risk and decide on the need for DEG testing on each containertaking into account the following:
Regular audits, no critical observation, no major related to traceability Manufacturing & packaging conditions Traceable distribution channels Transportation Good quality history Containers sealing integrity Containers aspect/integrity and labelling Use for parenteral (note : If yes, then high risk) Good service history
Evaluate the risk of fraud
Decide on the DEG testing.
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Testing OperationsRequirements (5)
The decision tree diagram below determines the extent of DEGtesting required:* Composite sample size: 1 composite sample derived from no more than 5 individual samples
GlycerolDirectly
Supplied byManufacturer
Suppliedfrom ICHLocation
CertifiedSupplier?
RiskAssessment
DEGTesting onCompositeSamples*
DEG Testing on Each Container
YES YESYES
NONO
NO
HIGH
RISK
LOW
RISK
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Thank You
Any Questions