EU Guidelines For Outsourced Activities Any activity covered by the GMP Guide that is outsourced should be appropriately defined, agreed and controlled in order to avoid misunderstandings which could result in a product or operation of unsatisfactory quality. There must be a written Contract between the Contract Giver and the Contract Acceptor which clearly establishes the duties of each party. The Quality Management System of the Contract Giver must clearly state the way that the Qualified Person certifying each batch of product for release exercises his full responsibility
1 There should be a written Contract covering the outsourced activities, the
products or operations to which they are related, and any technical arrangements
made in connection with it.
2 All arrangements for the outsourced activities including any proposed changes
in technical or other arrangements should be in accordance with regulations in force,
and the Marketing Authorisation for the product concerned, where applicable.
3 Where the marketing authorization holder and the manufacturer are not the
same, appropriate arrangements should be in place, taking into account the principles described in this chapter.
The Contract Giver
4 The pharmaceutical quality system of the Contract Giver should include the
control and review of any outsourced activities. The Contract Giver is ultimately
responsible to ensure processes are in place to assure the control of outsourced
activities. These processes should incorporate quality risk management principles and notably include:
5 Prior to outsourcing activities, the Contract Giver is responsible for assessing
the legality, suitability and the competence of the Contract Acceptor to carry out
successfully the outsourced activities. The Contract Giver is also responsible for
ensuring by means of the Contract that the principles and guidelines of GMP as
interpreted in this Guide are followed.
6 The Contract Giver should provide the Contract Acceptor with all the
information and knowledge necessary to carry out the contracted operations correctly in accordance with regulations in force, and the Marketing Authorisation for the product concerned. The Contract Giver should ensure that the Contract Acceptor is fully aware of any problems associated with the product or the work which might
pose a hazard to his premises, equipment, personnel, other materials or other products.
7 The Contract Giver should monitor and review the performance of the
Contract Acceptor and the identification and implementation of any needed
improvement.
8 The Contract Giver should be responsible for reviewing and assessing the
records and the results related to the outsourced activities. He should also ensure,
either by himself, or based on the confirmation of the Contract Acceptor’s Qualified
Person, that all products and materials delivered to him by the Contract Acceptor have been processed in accordance with GMP and the marketing authorisation.
The Contract Acceptor
9 The Contract Acceptor must be able to carry out satisfactorily the work
ordered by the Contract Giver such as having adequate premises, equipment,
knowledge, experience, and competent personnel.
10 The Contract Acceptor should ensure that all products, materials and
knowledge delivered to him are suitable for their intended purpose.
11 The Contract Acceptor should not subcontract to a third party any of the work
entrusted to him under the Contract without the Contract Giver’s prior evaluation and
approval of the arrangements. Arrangements made between the Contract Acceptor
and any third party should ensure that information and knowledge, including those
from assessments of the suitability of the third party, are made available in the same
way as between the original Contract Giver and Contract Acceptor.
12 The Contract Acceptor should not make unauthorized changes, outside the
terms of the Contract, which may adversely affect the quality of the outsourced
activities for the Contract Giver.
13 The Contract Acceptor should understand that outsourced activities, including
contract analysis, may be subject to inspection by the competent authorities.
The Contract
14 A Contract should be drawn up between the Contract Giver and the Contract
Acceptor which specifies their respective responsibilities and communication
processes relating to the outsourced activities. Technical aspects of the Contract
should be drawn up by competent persons suitably knowledgeable in related
outsourced activities and Good Manufacturing Practice. All arrangements for
outsourced activities must be in accordance with regulations in force and the
Marketing Authorisation for the product concerned and agreed by both parties.
15 The Contract should describe clearly who undertakes each step of the
outsourced activity, e.g. knowledge management, technology transfer, supply chain,
subcontracting, quality and purchasing of materials, testing and releasing materials, undertaking production and quality controls (including in-process controls, sampling
and analysis).
16 All records related to the outsourced activities, e.g. manufacturing, analytical
and distribution records, and reference samples, should be kept by, or be available to,
the Contract Giver. Any records relevant to assessing the quality of a product in the
event of complaints or a suspected defect or to investigating in the case of a suspected falsified product must be accessible and specified in the relevant procedures of the Contract Giver.
17 The Contract should permit the Contract Giver to audit outsourced activities,
performed by the Contract Acceptor or his mutually agreed subcontractors.
Reference:-
- EU Guideline For Outsourced Activities – EUDraLex Volume -4 Chapter 7