Implementation of GMP in Laboratory Facilities
Leimen, 09 Feb 2025
Introduction
Good Manufacturing Practice (GMP) is a system that ensures products are consistently produced and controlled according to quality standards. It is designed to minimize the risks involved in pharmaceutical production that cannot be eliminated through testing the final product. This white paper outlines the implementation of GMP in laboratory facilities, focusing on compliance with the German Medicinal Products Act (Arzneimittelgesetz, AMG) [1], Ordinance for the Manufacture of Medicinal Products and Active Pharmaceutical Ingredients (Arzneimittel- und Wirkstoffherstellungsverordnung — AMWHV) [2] and the International Council for Harmonisation (ICH) guidelines [3].
Regulatory Framework
Pharmaceutical manufacturers are required to obtain a manufacturing authorization. However, the process can be more complex for laboratories performing analyses on behalf of these manufacturers. One possible certification for such laboratories is the GMP manufacturing license for quality control. The options available and the specific requirements for each are beyond the scope of this document. In this paper, we will be focusing on the focus areas and categories to initiate the implementation of GMP.
Key Considerations for GMP Implementation
- 1
For the Quality Management System (QMS), conduct a quality assurance program with designated personnel in accordance with GxP regulations. Document the implementation of relevant guidelines in written instructions, including Standard Operating Procedures (SOPs).
- 2
Implement Quality Risk Management (QRM) for all quality-related changes to equipment, instruments, and analytical methods. Identify potential risks, assess their impact on quality, and define actions to mitigate risks to an acceptable level, followed by implementing risk control measures.
- 3
Ensure that there are sufficient qualified Personnel available to perform GMP analyses. Develop an organization chart that clearly outlines the quality structure of the organization. Establish comprehensive job descriptions and a training matrix, tailored to these job descriptions.
- 4
Compile a comprehensive list of major laboratory Equipment, outlining the periodic calibration and qualification of equipment for GMP analytics. Develop and document qualification procedures that include Design Qualification (DQ), Installation Qualification (IQ), Operational Qualification (OQ), and Performance Qualification (PQ).
- 5
For category Validation and Qualification, prepare a comprehensive validation master plan that includes a detailed list of activities, an inventory of equipment and systems, and a catalog of computerized systems. Establish and implement a process for periodic requalification and revalidation. Describe procedures to ensure the ongoing maintenance of qualified and validated status for all systems and equipment.
- 6
With regard to Analytical Testing, it is essential to establish written procedures for the collection and documentation of raw data. These procedures should include the verification of accuracy and completeness by a second person. Additionally, outline the procedures for method development, method validation, and the transfer of test methods.
- 7
For the Quality Documentation category ensure that comprehensive written procedures are in place for the generation, review, evaluation, and approval of GMP-compliant documents. The Quality Assurance (QA) department is responsible for managing GMP quality documents. Key components include the Site Master File / Quality Handbook, policies and processes, Standard Operating Procedures (SOPs), forms and templates.
- 8
For Supplier Management, it is essential to establish written procedures for the identification and selection of potential suppliers. Implement a system to categorize suppliers based on risk assessment criteria. Ensure thorough supplier qualification, including self-questionnaire forms and audits. Create and maintain an up-to-date database of all qualified suppliers. Conduct periodic reviews of qualified suppliers to ensure ongoing compliance and performance.
- 9
With regard to Change Control, the following measures are to be implemented:
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- a. Define comprehensive procedures for reporting deviations and changes that affect quality.
- b. Develop and enforce processes for evaluating, documenting, and approving deviations and changes.
- c. Implement procedures for initiating necessary corrective and preventive actions (CAPA).
- d. Establish and maintain a database to track and manage changes.
-
- 10
Establish a risk-based audit plan for Self-inspections and Audits. Begin by defining the audit objectives and identifying the audit team. Specify the areas to be audited and develop a detailed audit agenda. Conduct the audit, then prepare and evaluate the audit report. If necessary, define and implement action items based on the findings.
- 11
Define and implement processes for both short-term and long-term Archiving. Evaluate the use of external archiving services and ensure supplier qualification. Identify which GMP-critical documents need to be archived and specify their respective storage durations. Establish comprehensive procedures for the archiving of electronic data.
All these categories are designed to provide a structured framework in the laboratory during the introduction of GMP status. This project spans from several months to several years and requires substantial time and financial investment.
Conclusion
Implementing Good Manufacturing Practice (GMP) in laboratory facilities necessitates a comprehensive understanding of regulatory requirements and meticulous planning. By adhering to the guidelines established by the German Medicines Act (AMG), the Ordinance on the Operation of Pharmaceutical Enterprises and Pharmacies (AMWHV), and the International Council for Harmonisation (ICH), laboratories can ensure best practices and maintain high standards of quality and compliance.
For more information, please contact:
Dr. Anamarija Curic
CEO
Nuvalore GmbH
anamarija.curic@nuvalore.com
References
[1] Federal Ministry of Justice, „AMG,“ [Online]. Available: https://www.gesetze-im-internet.de/englisch_amg/. [Accessed 2025].
[2] Federal Ministry of Justice, „AMWHV,“ [Online]. Available: https://www.gesetze-im-internet.de/amwhv/.
[3] The International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH), [Online]. Available: https://www.ich.org/page/quality-guidelines.
[4] COMMISSION DELEGATED REGULATION (EU) No 1252/2014, „EUR-Lex,“ [Online]. Available: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014R1252.
[5] Directive 2001/83/EC , „Official Journal of the European Union,“ 14 10 2003. [Online]. Available: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2003:262:0022:0026:en:PDF.
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