How to Conduct an Audit of an Outsourcing Provider - There are several considerations to keep in mind when auditing an outsourcing provider. - BioPharm International

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How to Conduct an Audit of an Outsourcing Provider
There are several considerations to keep in mind when auditing an outsourcing provider.


BioPharm International Supplements


The final approval of an outsourcing provider should be dependent on both the written approval of the sponsor company's facility management and its quality assurance (QA) department. It is not sufficient for management to approve a provider without the approval of QA, and QA cannot solely approve a provider. It is usual to manage this process under the remit of a department concerned with the management and approval of providers. The provider should then be formally listed on a register of approved providers.

Following the Audit: The Technical and Quality Agreement

Before commencement of any service provision, a technical or quality agreement should be in place covering the services provided.4 In the US, this agreement is not required but is expected; in Europe, the agreement is mandatory. This technical or quality agreement must detail the service provided, quality requirements, and the responsibilities attributed to the contract giver and the contract acceptor. The agreement should be reviewed at a defined interval. This may be done following routine re-assessment of the provider.

Re-assessment

All approved service providers are required to be reviewed and re-approved at regular intervals.4 It is advantageous for sponsor companies to develop a formal program of re-approval that includes all providers, from the minor to the critical. As a part of this routine process, all approved outsourcing providers can be re-assessed at a predefined interval to ensure continued compliance with regulatory requirements and the agreements that are in place. Annual auditing is the usual practice, although a longer interval may be acceptable if justified. Re-assessments will usually entail a re-audit following the standard process outlined above and a re-approval to confirm the approval status or, if necessary, to remove the providers from the approved list.

An important consideration here is the change control process mandated by cGMP regulations. If a re-assessment audit shows a provider's performance to be unsatisfactory, then a formal risk assessment must be conducted to assess the impact on any product manufactured since the last audit and, ultimately, to assess the safety of the product and patient.

In between the established dates for re-approval, it is important for sponsor companies to continuously monitor the performance of providers. If the provider's performance begins to falter, the provider's approved status may need to be re-assessed ahead of the established schedule. Examples could be failure to supply a starting material that meets pre-defined specifications or to meet established deadlines. A well-maintained history of performance will allow trend analysis and the potential to stop problems before they become critical.

Conclusion

Regulatory requirements demand that outsourcing providers be part of a system that approves them as fit for purpose. The process of provider selection and approval must be part of the formal quality management system.

Andy McCallum is a quality assurance manager for Tepnel Research Products and Services' pharmaceutical outsourcing division, Livingston, UK, +44 (0)1506 424270,

References

1. Rules and Guidance for Pharmaceutical Manufacturers and Distributors 2007, MHRA, Pharmaceutical Press, London: 2007.

2. US Food and Drug Administration. Guidance for industry. CGMP in manufacturing, processing, packing, or holding of drugs; cGMP for finished pharmaceuticals. Rockville, MD; 2006.

3. PIC/S Secretariat. Pharmaceutical Inspection Cooperation Scheme. (See publications/recommendations.) http:// http://www.picscheme.org/index.

4. Medicines & Healthcare Products Regulatory Agency. Guidance on good manufacturing practices, Part 1: Basic requirements for medicinal products. In: Rules and Guidance for Pharmaceutical Manufacturers and Distributors. London: Pharmaceutical Press; 2007. p 80–81.


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