This is about identifying and defining the risks. The MHRA write:
“Many companies present such summaries as a spreadsheet which assists
communication, an essential part of QRM. The summary should be regularly
re-evaluated and potential changes assessed during quality management review
meetings. It is rare to find sound scientific justification for acceptance of a
load subject to an excursion, and in the uncommon instances where a supplier or
customer contacts the marketing authorization holder for stability information,
it is often not directly comparable to the excursion experienced.
Unfortunately, the most common reason for accepting a consignment with a
temperature excursion is purely commercial, which may put patients at risk and
undermines any risk management carried out by the company.
In some cases of quality risk management, attempts were made to
inappropriately apply mean kinetic temperature to underestimate impact rather
than develop good control and preventive measures.”
Posted by Dr. Tim Sandle, Pharmaceutical Microbiology Resources (http://www.pharmamicroresources.com/)
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