Technical services Flashcards
(167 cards)
Medicines Act 1968 - related to extemporaneous prep
Sections 7 & 8
- manufacture or assemble any medicinal product
- sell, supply or export any medicinal product
- procure the manufacture or assembly of any medicinal product for sale, supply or exportation
Section 9
Does not apply to doctors or dentists
Section 10
Exemptions for pharmacists
What is the orange Guide (1971)
- promote Good Manufacturing Practice by recommending steps taken by manufacturers to ensure that their medicinal products are of the good quality
- Uniting the main pharmaceutical regulations, directives and guidance expected when making medicinal products
- Compliance is a legal requirement within the EEA
Breckenridge Report (1976)
Increasing frequency of IV administrations plus increasing complexity of reconstitution and administration requirements, plus increasing complexity of drug regimens equals increased potential for error
Conclusion – reconstitute centrally within the hospital pharmacy
Result – CIVAS/TPN/Chemotherapy
Farwell Report (1995)
- Detailed approved operational procedures
- Defined responsibilities, competencies, training and performance of staff involved in the activity
- Control of all materials, including containers, devices and packaging, used in the processes.
- Consistent approach to product presentation including labelling
- Full documentation of systems and processes and other product-related issues, e.g., customer complaints
QAAPS (5th Edition)
Quality Assurance of Aseptic Preparation Services
- NHS response to loss of Crown Immunity and to MCA “Guidance to the NHS on the licensing requirements of the Medicines Act 1968.”
- Nationally agreed quality standards for preparation of aseptic products within the NHS
Supervision & Responsible Pharmacist Regulations
- Responsible Pharmacist regulations do not apply easily to Section 10 aseptic activities
- Permission to carry out activities under Section 10 exemption from Medicines Act requires pharmacist supervision but not physical presence
- Supervision for aseptic preparation is not specifically defined
- Scope to define “good practice” for this area
- Product approval pilot outcome to redefine good practice based on evidence
Section 10 exemption vs. MHRA Specials licence
Specials manufacturer licence
Preparation by any suitably trained person
Extended expiry
Batches prepared for stock
Final check and release must be done by separate people (any registered)
External MHRA inspection
Section 10 exemption
Prepared or directly supervised by a pharmacist
Max 7 day expiry
Prepared against a prescription
Final check and release done together by any suitably qualified person
What is a quality management system?
Quality Management System (QMS) –
A structured system that documents processes, procedures, and responsibilities for continuously delivering high-quality products and services that meet regulatory and customer requirements.
The objective of a quality management system is to provide a framework that improves communication, collaboration, and consistency while also reducing waste, and promoting continuous improvement.
What is a quality management system for pharmaceutical products?
Manufacturers must make medicines that are fit for their intended use and do not put patients at risk due to inadequate safety, quality or efficacy
The manufacture of pharmaceutical products requires the establishment and implementation of an effective ‘quality management system’ (QMS)’
The basis of an effective QMS in the production of pharmaceutical products must include the concepts of :
Good Manufacturing Practice (GMP)
Quality Control (QC)
Quality Assurance (QA)
What do I need to know about PQS?
Applicants to become a Qualified Person (QP) will be expected to demonstrate a thorough understanding of the following:
- the basic principles of QA;
- the design criteria for effective QMS
- auditing and self inspections
- deviations and change control
- documentation and record keeping
- the interpersonal skills necessary to implement an effective QMS
- the concepts of risk management
- the principles of design, selection, qualification and maintenance
- the principles of purchasing and supplier certification
What is Good manufacturing practice (GMP)?
- Good manufacturing practice (GMP) is the minimum standard that a medicines manufacturer must meet in their production processes
Products must:
- be of consistent high quality
- be appropriate to their intended use
- meet the requirements of the MA
What is Good manufacturing practice (GMP)
Legal framework?
- The legal framework for GMP are stated in a number of EU Directive’s which set out the principles and guidelines of GMP in the EU and UK.
- The GMP regulations establish mandatory, minimum requirements
- For the preparation of medicines, the RP is responsible for GMP
- Compliance is not an option or a matter of choice
- Complying with GMP is the lowest acceptable quality standard
What is Quality Control?
- The quality of a drug is critical for patient safety and effective treatment.
- If a drug is contaminated or not pure, it could cause harm to patients.
- If a drug is not potent enough, it may not be effective in treating the condition for which it was intended
QC is part of Good Manufacturing Practice which is concerned with:
- Inspecting, Sampling, and Testing the final product for adherence to specified quality standards.
- Products are examined and tested against predetermined criteria to identify and correct deviations from quality standards.
- Products may be tested during different stages of manufacture.
- QC covers detailed documentation of test results and release procedures.
- QC provides a feedback loop for future process enhancements
- QC ensure that the necessary and relevant tests are carried out and that materials are not released for use, until their quality has been judged to be satisfactory.
- QC involves identifying product defects and fixing these problems
What is Quality Assurance?
- Quality Assurance (QA) is a systematic approach aimed at ensuring the quality of a product throughout its lifecycle
- QA in manufacture is a series of well-defined and documented processes, providing a foundation for consistent, high-quality products.
- Quality assurance aims to prevent mistakes and defects and manage quality through defining processes, establishing standards and developing guidelines
- Each step of production should be carried out by a validated process aimed at assuring quality.
- QA focuses on defect prevention, aiming to reduce errors in the final product by identifying and mitigating potential risks early in the process.
- QA is focused on the entire process of manufacture
How do we design an effective PQS?
- Manufacturers must make medicines that are fit for their intended use and do not put patients at risk due to inadequate safety, quality or efficacy
- The basis of an effective QMS in the production of pharmaceutical products must include the concepts of :
- Good Manufacturing Practice (GMP)
- Quality Control (QC)
- Quality Assurance (QA)
How do you know your PQS is working?
Key Performance Indicators
- Statistical Process Control
- Trends
- People surveys
- Deviations
- Opinions
- Audits
- Customer Feedback
Limitations of PQS
- Cost of quality
- Documentation
- Processes
- Detail
- Knowledge Management
Specials and unlicensed medicines
- Medicines Licensed in Europe or elsewhere but not on sale in this country
- Medicines for a specified patient in accord with a prescriber’s instructions
- Medicines obtained from holders of a manufacturer’s “specials” licence e.g. hospital or a commercial: liquid formulations, low dose products for children, colour or allergen free
- Re-packed medicines generally used in accordance with the licence (changing the packaging means it is no longer licensed)
- Product is not a medicine but used to treat a rare condition (e.g. metabolic disorders)
- Prepared under a Section 10 exemption.
Licensed vs Specials - Legal differences
- If medicine is used within the terms of the licence (e.g. at the stated dose and for the indication specified in the SPC) any untoward effects are the legal responsibility of the manufacturer
- If a patient experiences a side effect (even one not specified in the SPC) then patients would have grounds to prosecute the manufacturer
- This is not the case for a pharmaceutical special
- As there is no SmPC, the prescriber takes full responsibility in law for any adverse effects caused by the medicine (unless proven faulty)
Legal Matters
- Manufacture and sale or supply of medicines was first brought under legal control by The Medicines Act 1968
- Subsequently incorporated into European law by EEC Directive 65/65 amended following Brexit in Jan 2021, but essentially the same
- Updated into Human Medicines Regulations 2012 which requires that:
- All Medicines are licensed before they may be sold or supplied in the UK (with post Brexit amendments 2019 and 2020) (with section 10 exemptions)
Conditions of section 10 exemptions
As a pharmacist you must have:
Bona fide unsolicited order
Product is formulated for a specified patient in accordance with the requirement of a practitioner registered in the UK
As a pharmacist you must be sure:
- Product is for use by your individual patients on their direct personal responsibility
broadly includes any form of extemporaneous dispensing, including TPN compounding, IV additives and cytotoxic reconstitution
- If a ‘special’ is manufactured in the UK, the manufacturer must hold a manufacturer’s (specials) licence from the MHRA and / or an Investigative Medicinal Products (Clinical Trials) Licence
- Pharmacies must have the appropriate equipment and facilities available to produce a high quality, safe product
- Serious adverse drug reactions reported to MHRA (Yellow Card Scheme
A ‘special’ may not be advertised
- Because “specials” have no product licence they cannot be offered for sale by a manufacturer, but must be procured or commissioned by a purchaser
- “Specials” manufacturers can advertise their services only
- The Medicines for Human Use (Advanced Therapy Medicinal Products and Miscellaneous Amendments) Regulations 2010 amended the legislation and allowed price lists be published
- Because of the bespoke nature of some specials, it’s not be possible for all unlicensed medicines to be included in price lists
Risk assessment: what’s on it?
- The risk assessment for unlicensedmethods should state what the risks are
and whether an equivalent relevant licensed product exists and is available
It should also include (GphC standard)
formula from a recognised source e.g.
- Pharmacopeia
- Method validation
- Calculation verification
- Need/use of specialist equipment
- Contamination & hygiene measures
product-specific risks
- Suitability of premises
- Staff skills / knowledge / training / competence
Essential records must be kept
A record should be kept, including as a minimum
- name of product;
- specification;
- prescriber’s name, if appropriate;
- manufacturer and (if different) supplier;
- date ordered;
- quantity ordered;
- batch number received
- Retained for least 5 years