The inter-agency Pharmaceutical Inspection Cooperation Scheme (PIC/S) has released an “Aide-Memoire” intended to assist GMP inspectors in assessing industry’s implementation of quality risk management (QRM) and to help promote a harmonized approach among PIC/S member states.
The Aide-Memoire notes that QRM aspects should be integral to the planning and content of all GMP inspections, including those involving both final products and active pharmaceutical ingredients (APIs).
PIC/S clarifies that the existence of this separate QRM document “does not suggest that specific inspections for QRM systems are performed.” Instead, the goal is to focus during general inspections on how the company has integrated QRM into its operations.
The Aide-Memoire was adopted by the PIC/S in mid-March, and became effective on April 2.
What reviewers and inspectors will look for in their assessment of QRM has been drawing a good deal of discussion at public forums in the wake of ICH’s refinement of the underlying principles, as the agencies and industry work to incorporate them into regulatory and quality system processes.
The PIC/S guide is an effort to help address some of the questions that the expanding emphasis on QRM raises. Given the current breadth of PIC/S membership, which now includes FDA, the new guide has significant implications for inspection practice in the evolving quality regulatory paradigm.
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