Extreme care needs to be taken when outsourcing pharmaceutical contract manufacturing
Starting in
about the early 2000’s; there have been rather huge and dramatic strides
by the pharmaceutical industry in the area of outsourcing. This was on a scale
that was unmatched in the industry’s history. Although globalization was set in
motion about a decade or so earlier; it started gathering steam around this
time. When so many products and services could be outsourced, it was natural
that attention was turned towards outsourcing in the pharmaceutical industry,
as well.
However,
outsourcing in this particular area has its own set of peculiarities, which was
to be taken note of. Since this is an industry in which the products can play
within the lives of people; it was expected that pharmaceutical outsourcing had
to be approached and treaded very cautiously. At the smallest deviation from
the prescribed standards; the FDA and other regulatory agencies come down
heavily on the pharmaceutical unit, and quite understandably so.
FDA regulations have to be complied with in
toto
The FDA issues
483’s and Warning Letters to pharmaceutical manufacturing units that fail to
comply even to the smallest extent with its highly stringent prescribed
standards. This being the case, it is natural that these players in the
industry have to take all the necessary steps to ensure that the contract
laboratory or manufacturer to which it outsources meets all the standards set
out by the FDA and other regulatory bodies.
This is
absolutely necessary because of the high risk that these laboratories face in
outsourcing to contract labs. The risk accrues mainly because of one factor:
Drug products and API's that are finished at these contract laboratories are
released straightaway into the market without further checks. This is why the
FDA and other regulatory agencies attach the highest importance to inspections
in the contract laboratories.
Reference to an industry guideline
How do parent
laboratories and contract laboratories go about their outsourcing method? They
have a handy and reliable guideline to refer to. Considering the high scale and
nature of outsourcing; the Active Pharmaceutical Ingredients Committee (APIC),
in collaboration with the Council of European Federations for the Chemical
Industry (or CEFIC in French) developed a guideline in 2010 for the conduct and
best practices to be implemented in the area of supplier management in contract
manufacturing.
This guideline
serves as a good indicator of the way the industry works today. The initial
focus of this guideline was on those who supplied materials to those in the
business of API manufacturers. The creators of this guideline have acknowledged
the need to expand this study to include Laboratory Contract Lifecycle
Management into it as part of the next phase of the research. The aim of this
study is to ensure that patients get the confidence that they have access to
medicines that are safe and have high quality and efficacy, despite the
variance of the cGMP documentation from one country to another or one region to
another.
Guidelines on all areas of the
manufacturing process
This document,
considered among the authoritative guides for best practices for contract
manufacturing; sets out systems that have to be implemented during the entire
lifecycle of the product for managing contract laboratories. The stages include
all the steps from the first to the end:
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