This presentation provides an overview of the role that a computerized quality management system plays in a manufacturer practising Good Manufacturing Practices and compares it's complimentary functions against an Enterprise Resource Planning System
3. Regulations and Regulators
Europe – Directive 2003/94/EC (EU
Regulators)
◦ GMP: “the part of quality assurance which ensures
that products are consistently produced and
controlled in accordance with the quality standards
appropriate to their intended use”
USA – F,D&C Act, Federal Codes (FDA)
◦ “… the minimum current good manufacturing
practice for … the manufacture, processing,
packing, or holding of a drug to assure [safety,
identity, strength, quality and purity]”
4. The GxP’s
“Good x Practice”
◦ Good Clinical Practice
◦ Good Distribution Practice
◦ Good Laboratory Practice
◦ Good Manufacturing Practice
GxP Controls to are required to minimize
risks to
◦ Patient Safety
◦ Product Quality
◦ Data Integrity
5. Objective
“Our primary focus will remain the same:
to minimize the risks to the public health”
- Department of Health and Human
Services, U.S. Food and Drug
Administration
6. Laws, Regulations and Guidance
Law, e.g.
◦ Food, Drug & Cosmetic Act, EU Directive
Regulations, e.g.
◦ 21 CFR 211, 21 CFR 820, EU GMPs
Guidance, e.g.
◦ FDA Guidance on Part 11 Scope and Application
7. The Food, Drug and Cosmetic Act
“A drug or device shall be deemed to be
adulterated … if it is a drug and the methods
used in, or the facilities or controls and the
methods used in, or the facilities or controls used
for, its manufacture, processing, packing, or
holding do not conform to or are not operated or
administered in conformity with current good
manufacturing practice to assure that such drugs
meet the requirements of this chapter as to
safety and has the identity and strength, and
meet the quality and purity characteristics, which
it purports or is represented to possess…”
8. 21 CFR 211.68 Automatic,
Mechanical and Electronic
Equipment
Must
◦ Perform a function satisfactorily
◦ Calibrated, inspected or checked according to a
written programme
◦ Controlled in use
◦ The data is secure
◦ Outputs are accurate
◦ Adequately backed up, maintained and
documented
◦ Under change control
9. GAMP 5, ICH Q9
“Manufacturers should be able to justify
their standards, protocols, acceptance
criteria, procedures and records based on
their risk assessment”
11. Records and Signatures
Records that are required to be maintained under
predicate rule requirements and that are maintained
in electronic format in place of paper format
Records that are required to be maintained under
predicate rules that are maintained in electronic
format in addition to paper format, and that are relied
upon to perform regulated activities
Records submitted to FDA under predicate rules
(even if such records are not specifically identified in
Agency regulations) in electronic format.
◦ - FDA Scope and Application Guidance
12. Elecronic Record
Electronic record means any combination
of text, graphics, data, audio, pictorial or
other information representation in digital
form that is created, modified,
maintained, archived, retrieved, or
distributed by a computer system
13. Electronic Signature
Electronic signature means a computer
data compilation of any symbol or series
of symbols executed, adopted, or
authorized by an individual to be the
legally binding equivalent of the
individual’s handwritten signature
14. Validation of Systems
Validation of systems to ensure accuracy,
reliability, consistent intended
performance and the reliability to discern
invalid or altered records
This clause is currently under enforcement
discretion
15. Protection
Protection of records to ensure their
accurate and ready retrieval throughout
the records retention period
16. Record Retention
Must meet predicate rule requirements
and preserve content and meaning
Decision how should be based on
predicate requirements, a justified and
documented risk assessment, and
determination of the value of the records
over time
17. Audit Trail
Secure, computer generated timestamped
audit trails to independently record the
date and time of operator entries and
actions that create, modify or delete
electronic records
18. Quality Management System
Quality Modules
• Risk Management
• Document Management
• Project Management
• Process Management
• IT Services Management
• Product Life Cycle Mgt
• Competency
Management
• Asset Management
• Preventive/Corrective
Actions
• etc
19. ERP
ERP Functions
◦ General Ledger
◦ Purchasing
◦ Inventory
◦ Sales
◦ Accounts Receivables
◦ Accounts Payables
◦ Production Planning & Control
Logistics
Production Schedule
Job Costing
◦ etc
20. Differences
Quality Management Systems ERP Systems
Data related to Quality Management
• Quality documents, policies, SOP,
procedures, checklist
• Project plans eg product lifecycle
management activities: prepare specs,
drawings, acceptance, tooling, training
• Quality related workflows
• Preventive/ corrective actions:
equipment maintenance, customer
complaints, incoming QC
• Risk management – identification,
quantification, control plan, monitoring
• Quality related KPIs – reworks,
downtime, deadlines
• Staff training – evaluation, training
needs, scheduling, certification
Financial, manufacturing and logistic data
• Order entry, deliveries, sales invoicing,
accounts receivables
• Purchase requisitions, purchase orders,
deliveries, accounts payables
• Cash and payment management, bank
reconciliation, cashflow reporting
• Manufacturing plans, production
scheduling
• Inventory management, receipts,
issuance, stock levels, transfers
• Facility management, fixed asset
register, acquisitions, disposals,
depreciation
• Human resource management, payroll,
taxes
21. Comparison of ERP to Quality
Management System
Quality Management Systems
complement ERP Systems
Quality Management Systems manages
quality documents, processes, people,
facilities and assets, materials
ERP systems manages accounting and
logistics aspects of finance, production,
inventories
29. Integration Points – Core Module
Personnel – staff/user id, departments,
teams, positions, roles
Business Units, Organization Units
Business Calendar
30. Process Integration – Sales/ Production
Predefined
Parts
Custom
Order
Production
Sales
Support
QMS ERP
• Specifications Docs
• Drawings
• Project Planning
• Specifications/
Drawings – Revision
Control/ Acceptance
• Commercial Proposal
Docs
• Change Management
• Quality Records
• Quality KPIs
• Process Risks
• Logistics Document
Capture/ Storage
• Corrective Actions
• Parts Definitions
• Parts Details/ Std
Costs
• Sales Quotation
• Order Entry
• Subcontractors
Quotations
• Credit Control
• Production Planning/
Control
• Inventory
• Cost Accounting
• Delivery Order
• Invoicing
• Accounts Receivables
31. Integration Points - Production
Item types
Part numbers
Part details eg descriptive details, alias
names
Equipment ID
Process/ Run / Batch ID and details
Customer names and details
Subcontractor names and details (if
applicable)
35. Integration Points – Fixed Assets
Equipment ID and details
Supplier ID and details
Maintenance service providers ID and
details
Maintenance/ calibration records and
schedules