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The Master Guide to Quality Risk Management (QRM) in Sterile Manufacturing: An ICH Q9 Perspective

  1. Introduction: From Reactive to Proactive Quality ​In the high-stakes environment of sterile injectables, waiting for a failure to occur is not an option. Quality Risk Management (QRM) is the systematic, proactive process of assessing, controlling, communicating, and reviewing risks to product quality. Drawing from my 11+ years of experience navigating USFDA and MHRA audits.  I have seen that a robust, scientifically sound QRM program is the fundamental difference between a minor observation and a severe Warning Letter. ​ 2. The Regulatory Bedrock: Understanding ICH Q9(R1) ​The International Council for Harmonisation (ICH) provides the global standard through the Q9 guideline. The recent revision, ICH Q9(R1) , emphasizes reducing subjectivity and ensuring a scientific basis for risk assessments. ​ Patient Protection: The core purpose of QRM is to safeguard the patient; all evaluations must link back to patient health. ​ Proportionality: The level of effort and doc...

Changes In Revised Schedule M

Revised Schedule M in the pharmaceutical industry typically refers to updates or changes made to the guidelines outlined in Schedule M of the Drugs and Cosmetics Act in India. These guidelines are crucial for maintaining good manufacturing practices (GMP) in pharmaceutical manufacturing units. Here are some common changes or updates that might occur in a revised Schedule M:

1. Quality Management System (QMS) Enhancements:

 Updates to the requirements for implementing a robust Quality Management System, including documentation, training, and quality control measures.

2. Validation Requirements:

Changes in validation requirements for equipment, processes, and systems used in pharmaceutical manufacturing to ensure consistency and reliability.

3. Cleanroom Standards: 

Updates to cleanroom standards and environmental monitoring requirements to maintain a sterile manufacturing environment.

4. Personnel Training:

Emphasis on ongoing training and competency assessment for personnel involved in pharmaceutical manufacturing to ensure compliance with GMP standards.

5. Technology Upgrades:

Incorporation of new technologies and best practices for improving manufacturing processes, such as automation, data integrity measures, and electronic documentation systems.

6. Supply Chain Management:

Guidelines related to supply chain management, including procurement of raw materials, storage conditions, and distribution practices to prevent contamination or degradation of products.

7. Environmental Sustainability:

Inclusion of measures for environmental sustainability and waste management within pharmaceutical manufacturing facilities.

Link to download  click below link

revised schedule M guidelines 

Comparative table for revised schedule M updates

Let's compare the key aspects between the Existing Schedule M and the Revised Schedule M in the context of pharmaceutical quality standards:

These revisions aim to elevate quality management standards, foster innovation, and enhance patient safety in the Indian pharmaceutical industry.

Are there any penalties for non-compliance with Revised Schedule M?

Non-compliance with the Revised Schedule M can result in serious consequences for pharmaceutical manufacturers. Here are some potential penalties:

1. Regulatory Actions:

   - Regulatory authorities may issue warning letters, which serve as formal notices of non-compliance. These letters outline specific deficiencies and require corrective actions.
   - Suspension or cancellation of manufacturing licenses can occur if violations persist or are severe.

2. Financial Implications:

   - Fines and monetary penalties may be imposed based on the severity of non-compliance.
   - These fines can significantly impact a company's financial health.

3. Legal Consequences:

   - Legal proceedings may be initiated against the manufacturer.
   - Criminal charges could be filed in extreme cases of deliberate non-compliance.

4. Reputation Damage:

   - Non-compliance tarnishes a company's reputation.
   - Loss of consumer trust and credibility can have long-lasting effects.

Manufacturers must prioritize adherence to quality standards outlined in the Revised Schedule M to avoid these penalties and ensure patient safety. 

Conclusion:

These changes are typically made to align with international standards, improve product quality, ensure patient safety, and adapt to advancements in technology and best practices in the pharmaceutical industry.

Source: Conversation with Bing, 03/04/2024

(1) Existing Schedule M vs Revised Schedule M - sidvim. https://sidvim.com/pdf/insights/Comparison-New-Schedule-M-vs-Existing.pdf.

(2) Workshop For Regulators On Revision of Schedule M (GMP). http://aidcoc.in/pdf/38_Revised%20Schedule%20M.pdf.

(3) Pharmaceutical Quality: Key Amendments in Revised Schedule M. https://thehealthmaster.com/2023/10/17/pharmaceutical-quality-key-amendments-in-revised-schedule-m/.

(4) Revised Schedule M: Govt sets deadline for pharma industry. https://thehealthmaster.com/2023/10/02/revised-schedule-m-govt-sets-deadline-for-pharma-industry/.

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