Transport validation Anne Junttonen Finnish Medicines Agency Copenhagen 20.11.2014
Transport Validation Cannot be done? Can be done? Should be done? 20.11.2014 Anne Junttonen 2
Transport Validation Validation in EU GMP and GDP: Action of proving, in accordance with the principles of Good Manufacturing Practice, that any procedure, process, equipment, material, activity or system actually leads to the expected results (see also qualification). Transport is a mobile form of storage => similar level of control as for fixed sites Occurs in series between manufacturing site of shelf life day 0 and the retailer supplying the patients. 20.11.2014 Anne Junttonen 3
Expected result of transportation? Correct consignment from and to correct place in correct time and correct conditions by correct actors in compliance with the Quality System (GMP/GDP/contracts/SOPs ) each time* through all stages of manufacture, importation and distribution Quality of product intact, falsification ruled-out. *How many times? 20.11.2014 Anne Junttonen 4
Falsified Medicinal Product Any medicinal product with a false representation of: (a) its identity, including its packaging and labelling, its name or its composition as regards any of the ingredients including excipients and the strength of those ingredients; (b) its source, including its manufacturer, its country of manufacturing, its country of origin or its marketing authorisation holder; or (c) its history, including the records and documents relating to the distribution channels used. 20.11.2014 Anne Junttonen 5
Manufs?? MIAs MIAs/Repack WDAs retail Manufacture in tropics Distribution in arctics patient 20.11.2014 Anne Junttonen 6
Responsibility of transportation Total supply chain before batch release: After batch release: EU QP/MIA holder = 1. supplier MIA or WDA holder (or authorized retailer) as defined in a contracts / quality agreements between the supplier and recipient. Suppliers and recipients (up to retail) of medicinal products must be authorized. Storage of medicinal products: WDA/MIA Transportation is moving medicinal products between two locations* without storing them for unjustified periods of time. *authorized supplier/recipient 20.11.2014 Anne Junttonen 7
Temperature control The required storage conditions for medicinal products should be maintained during transportation within the defined limits as described by the manufacturers or on the outer packaging. If a deviation such as temperature excursion or product damage has occurred during transportation, this should be reported to the distributor and recipient of the affected medicinal products. A procedure should also be in place for investigating and handling temperature excursions. Cumulative impact of excursions? Any slack left for patient use? 20.11.2014 Anne Junttonen 8
Temperature validation / Temperature control Ability to show that the predetermined temperature conditions are met throughout the journey and the load. Temperature control during transportation. Risk assessment of delivery routes to determine where temperature controls are required. Qualified equipment e.g. thermal packaging, temperature-controlled containers or temperature controlled vehicles Equipment used for temperature monitoring should be maintained and calibrated at regular intervals at least once a year. Temperature mapping of temperature controlled vehicles under representative conditions should be carried out and should take into account seasonal variations. 20.11.2014 Anne Junttonen 9
Audit of your supply chain suppliers - The quality system should extend to the control and review of any outsourced activities - To verify supplier wholesale distributor s compliance with GDP - Contract Acceptors should be audited before commencement of, and whenever there has been a change to, the outsourced activities. - The frequency of audit should be defined based on risk depending on the nature of the outsourced activities. Audits should be permitted at any time. Audits can be contracted out to a third party. Responsibility remains by the contract giver. 20.11.2014 Anne Junttonen 10
Supply chain in control Only predetermined and qualified suppliers and subcontractors involved in all steps of manufacturing, importation and distribution. Checks that goods really come from the defined suppliers and by the defined logistics providers/transportation. Correct storage and transportation conditions can be verified for each delivery. Quality Risk Management to fill all gaps => Going well? 20.11.2014 Anne Junttonen 11
By courtesy of director Elina Aine, Santen Oy, Tampere, Finland Picture: Helsingin Sanomat March 2010 Stevedores' strike in Finland 20.11.2014 Anne Junttonen 12