The personnel is the most important asset of a company, and the easiest to neglect. The establishment and maintenance of a satisfactory system of quality assurance and GMP relies upon people who develop the system, the people who use the system and the people who examine the system to see if it has worked.
The technical people must have a knowledge and understanding of GMP to enable them to carry out their duties in accordance with GMP. These people must have the level of training and experience that will enable them to do their professional works respectively.
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Personnel.pdf
1. Module 8 | Slide 1 of 29 January 2006
GMP TRAINING
ON
PERSONNEL
Presented by:
MD. ZAKARIA FARUKI
Manager & Head of Quality Assurance
Silva Pharmaceuticals Limited
Date of Training: August 20, 2022
GMP
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2. Module 8 | Slide 2 of 29 January 2006
Personnel
Basic Principles of GMP
9
Companies can make investments and buy facilities and
equipment. However, the greatest resource that a
company has is its personnel. But human resources
also need a lot of attention. If a company does not have
correctly educated, trained and motivated people
working in its factory or laboratory, it is necessary to
provide training in order to overcome any inherent
weaknesses and to build upon existing strengths.
GMP
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3. Module 8 | Slide 3 of 29 January 2006
Personnel
Objectives
To review general issues related to personnel
To review requirements for key personnel
To review the training of personnel
To consider some specific issues
GMP
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4. Module 8 | Slide 4 of 29 January 2006
9.1
Personnel
Principle
Establishment and maintenance of satisfactory system of QA,
manufacture and control of products and actives rely on people.
Must be sufficient qualified personnel to carry out tasks
Individual responsibilities must be clearly defined and understood
by individuals concerned
Written job descriptions
All personnel should be aware of the principles of GMP that affect
them
GMP
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5. Module 8 | Slide 5 of 29 January 2006
9.2
Personnel
General (1)
Personnel requirements:
Adequate number of persons
With necessary qualifications
With practical experience
An individual’s responsibilities should not be so extensive as to
present a risk to quality
GMP
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6. Module 8 | Slide 6 of 29 January 2006
9.3
Personnel
General (2)
All responsible staff should have specific duties recorded in
individual written job descriptions
Have adequate authority to carry out responsibilities
May delegate to designated deputies with qualifications
No gaps or unexplained overlaps
Organization chart
GMP
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7. Module 8 | Slide 7 of 29 January 2006
Basic Principles of GMP
Organization Chart
This is NOT what
it should look like
GMP
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8. Module 8 | Slide 8 of 29 January 2006
9.4
Personnel
General (3)
All personnel should be aware of GMP
Must receive training in GMP:
initial training
continuing training
including hygiene standards
Motivated to
support the establishment
maintain high-quality standards
GMP
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9. Module 8 | Slide 9 of 29 January 2006
9.5
Personnel
General (4)
Prevent unauthorized access
To production areas
Storage areas
Quality control
Stop personnel who do not work in these areas using them as
passageways
GMP
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10. Module 8 | Slide 10 of 29 January 2006
Basic Principles of GMP
GMP
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11. Module 8 | Slide 11 of 29 January 2006
9.6
Personnel
Key Personnel (1)
Key personnel (which normally should be
full-time) positions include:
Authorized person
Head of Production
Head of Quality Control
May delegate functions – not responsibility
Heads of Production and Quality Control should be
independent of each other
Head of Quality - maintains all compliance issues of the
Organization.
GMP
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12. Module 8 | Slide 12 of 29 January 2006
9.7
Personnel
Key Personnel (2)
Should posses appropriate qualifications
Scientific education such as:
chemistry or biochemistry
chemical engineering
microbiology
pharmaceutical sciences and technology
pharmacology and toxicology
physiology; or
other related science subjects relevant to the responsibilities
to be undertaken
GMP
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13. Module 8 | Slide 13 of 29 January 2006
9.7
Personnel
Key Personnel (3)
Should posses appropriate experience
Practical experience
Manufacture and quality assurance
Preparatory period under professional guidance sometimes
needed
Education and experience should enable personnel to take
difficult decisions in an independent, professional and scientific
way
resolve the problems encountered in manufacturing and QC
GMP
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14. Module 8 | Slide 14 of 29 January 2006
Personnel
Shared Responsibilities (1)
Heads of Production and Quality Control may share/jointly exercise some
responsibilities relating to quality:
authorization of written procedures (SOPs) and other documents,
including amendments
monitoring and control of manufacturing environment & plant hygiene
process validation and calibration
training, including application and principles of QA
approval and monitoring of suppliers and contract acceptors
9.8
GMP
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15. Module 8 | Slide 15 of 29 January 2006
Personnel
Shared Responsibilities (2)
Designation and monitoring of storage conditions for materials
and products
Performing and evaluating in-process controls
Retention of records
Monitoring compliance with GMP
Inspection, investigation, and taking of samples to monitor
factors which may affect quality 9.8
GMP
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16. Module 8 | Slide 16 of 29 January 2006
Personnel
Head of Production: Responsibilities (1)
Product production and storage according to appropriate
documentation
Approval and implementation of production instructions,
in-process QC and ensure strict implementation
Ensures that production records are evaluated and signed by
designated person
9.9
GMP
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17. Module 8 | Slide 17 of 29 January 2006
Personnel
Head of Production: Responsibilities (2)
Checks maintenance of production department, premises and
equipment
Ensures process validation and calibration performed,
recorded, and reports are made available
Ensures initial and continuous training of production personnel
9.9
GMP
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18. Module 8 | Slide 18 of 29 January 2006
Personnel
Head of Quality Control: Responsibilities (1)
Approval or rejection of materials, e.g. packing materials,
intermediates, bulk and finished products, in accordance with
specifications
Evaluation of batch records
Ensures carrying out of necessary testing
Ensures of quality control procedures, e.g. sampling and testing;
specifications
9.10
GMP
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19. Module 8 | Slide 19 of 29 January 2006
Personnel
Head of Quality Control: Responsibilities (2)
Approval and monitoring of all contract analysis
Checks maintenance of quality department, premises and
equipment
Ensures validation (including analytical procedure validation)
and calibration of control equipment
Ensures initial and continuous training of QC personnel
9.10
GMP
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20. Module 8 | Slide 20 of 29 January 2006
Personnel
Authorized person: Responsibilities (1)
Compliance with technical and regulatory requirements
Approval of all procedures like SOP, SOP & GMP Documents
Approval of the release of finished product for sale
Establishment and implementation of quality system
Supervision of self-inspections and quality audits
Development of quality manual
9.11
GMP
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21. Module 8 | Slide 21 of 29 January 2006
Personnel
Authorized person: Responsibilities (2)
Oversight of the QC department
Participation in external audits and vendor audits
Participation in validation programmes
May delegate approval of release of product
through approved procedure
Normally by QA by means of batch review
9.12, 9.13
GMP
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22. Module 8 | Slide 22 of 29 January 2006
Personnel
Person releasing the batch should ensure: (1)
Each batch meets manufacturing and marketing authorization
requirements
Principles and requirements of GMP are met
All checks and tests have been performed
Production conditions and manufacturing records
Planned changes and deviations reported - including where
necessary to drug regulatory authority
9.14 a - e
GMP
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23. Module 8 | Slide 23 of 29 January 2006
Personnel
Person releasing the batch should ensure: (2)
Additional sampling, inspection, checks and tests had been
done when required
All production and control documents are completed and
endorsed
Audits, inspections and spot-checks were done
QC approval has been given
All other relevant factors have been considered
9.14 f - j
GMP
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24. Module 8 | Slide 24 of 29 January 2006
Personnel
Training (1)
Training, in accordance with a written, approved programme
all personnel whose duties take them into production areas; or
into control laboratories; and
for others whose activities could affect the quality of the
product including technical, maintenance and cleaning
personnel
Induction and continuing training
on theory and practice of GMP and their duties
training records should be kept
practical effectiveness checked
training before undertaking any new task
10.1, 10.2
GMP
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25. Module 8 | Slide 25 of 29 January 2006
Personnel
Training (2)
Specific training for staff in special areas, e.g.
Where contamination is a hazard
Including clean areas; or
Areas where highly active, toxic, infectious, sensitizing
materials are handled
The concept of QA should be fully discussed during training to
facilitate proper understanding to ensure its implementation
10.3, 10.4
GMP
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26. Module 8 | Slide 26 of 29 January 2006
10.5
Personnel
GMP
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Visitors or Untrained Personnel
Preferable not to enter production and control areas. If this is
unavoidable then:
They must be given information in advance, particularly about
personal hygiene
protective clothing requirements
Must be accompanied and closely supervised at all times
27. Module 8 | Slide 27 of 29 January 2006
10.6
Personnel
Consultants and contract staff
Should be qualified for the services provided
Training records maintained
Records should prove qualifications
GMP
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28. Module 8 | Slide 28 of 29 January 2006
Personnel
Group Session
What do you think will be the key personnel issues to arise
during an inspection?
What sort of responses do you think you should give to these
issues when they become apparent?
GMP
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29. Module 8 | Slide 29 of 29 January 2006
Personnel
Possible Issues – I
Limited number of staff
Inadequate qualifications
Inadequate experience
Owner interferes in quality decisions
Lack of means to develop training materials
GMP
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30. Module 8 | Slide 30 of 29 January 2006
Personnel
Possible Issues – II
Company procedures take precedence over local legislation
Unclear organization diagram
Staff movement
Inadequate training records
Illness
GMP
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31. Module 8 | Slide 31 of 29 January 2006
Personnel
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GMP
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