What Are The Elements of Quality Control Process
What Are The Elements of Quality Control Process
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What are the elements of quality control process in
pharmaceuticals
Published on: Oct 29, 2023
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Why do you need to implement a quality control process if you can manufacture products that are free from all
possible contaminants?
Can you create a system that can eliminate all defects from a product? If possible, this can eliminate the necessity
of quality control processes entirely. Until then, we must rely on quality control processes as part of quality
assurance systems.
The risk of compromised patient safety for pharmaceutical products outweighs the risk of having no quality
control process.
One of the main objectives of quality control is to test for product attributes that are known and expected. These
attributes are part of the product specification.
However, laboratory testing cannot pick up all product defects if your test is not validated to detect unknown
abnormalities. Your test may need to be more sensitive or may not be required for that product.
Companies, therefore, have to rely upon GMP rules and quality management systems to prevent these problems
from occurring in the first place.
It is critical to get accurate results from quality control tests. Otherwise, defective batches may be released, and
good batches may be rejected.
The role of the quality control laboratory is to detect any possible defects once they have occurred rather than to ←
prevent them from occurring in the first place.
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The quality control laboratory’s specific responsibilities include:
(a) The establishment of any specifications, standards, sampling plans, test procedures, or other laboratory
control mechanisms required by this subpart, including any change in such specifications, standards,
sampling plans, test procedures, or other laboratory control mechanisms, shall be drafted by the
appropriate organizational unit and reviewed and approved by the quality control unit.
(b) Laboratory controls shall include the establishment of scientifically sound and appropriate specifications,
standards, sampling plans, and test procedures designed to assure that components, drug product
containers, closures, in-process materials, labeling, and drug products conform to appropriate standards of
identity, strength, quality, and purity.
Some companies establish 100% in-line testing to generate additional assurance of quality.
After collecting the samples, they should follow a typical pathway inside the quality control laboratory, from
receiving, testing, and preparing the final report.
All laboratories maintain a sample-receiving register. This register logs the batch and sample number, the
number of samples provided, and the time and date the sample first entered the laboratory. This is the
commencement of sample tracking.
Many test methods require sample preparation before the test is run. The test method should describe
exactly how the sample is prepared. This may involve simple dilution or more complex extraction and
manipulation. Always refer to the current test method before setting up the sample.
Once the sample is prepared, it is included in the test run. Care must be taken to ensure that the sample is
not degraded, e.g., by spillage, exposure to the atmosphere, or temperature degradation on the bench.
Always refer to the current test method for instructions on how to protect the sample during testing. While
testing the sample, analysts should ensure that the instrument or a logbook records the sample number
and it is traced exactly to the test result.
This is called “system suitability testing” (SST). Non-instrumental methods may also include control or
equivalent verification systems. The test methods should describe how the integrity of particular test runs is
verified. ←
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v. Collect raw data and calculate results
Once the sample has been run, either the instrument or the analyst will perform a calculation to arrive at a
result. It is essential to double-check all calculations before finalizing sample results.
All quality control laboratories have written procedures for handling and investigating only results that
appear to be out-of-specification. The analyst should ensure that the supervisor is notified as soon as an
OOS event occurs, the sample is retained, and a documented investigation is commenced.
Once the sample has been run, either the instrument or the analyst will perform a calculation to arrive at a
result. It is essential to double-check all calculations before finalizing sample results.
The following are some common elements that are required to establish a good quality control process or system.
Laboratory quality manuals and policies sit at the top of the quality control process hierarchy.
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After establishing the laboratory manual, you must develop standard operating procedures as part of the
quality control documentation system to remain consistent in your activities within the quality control.
Written procedures should reflect the requirements of governing standards. There are some essential
procedures that are needed in almost all quality control processes.
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– Test method validation and control
– Sampling procedures
– Personnel training
Analytical test method validation guarantees that your test method is robust enough to provide evidence if
your product meets the predetermined product specification or conforms to the failure of a product.
Test method validation is the process by which it is established that the performance characteristics of the
test method, such as precision, accuracy, specificity, linearity, limit of detection (LOD), limit of quantitation
(LOQ), and robustness, meet the requirements for the intended applications.
Before commencing any assay, the analyst should refer to the current version of the test method. The test
method should be available at the worksite.
The quality control laboratory must process samples through qualified and calibrated instruments. The
analyst should be aware of the status of the instrument before conducting the test.
In particular, the analyst should pay attention to the instrument calibration status. Do not proceed with the
test if an instrument is out of calibration.
Upon introduction to the laboratory, all laboratory instruments should undergo formal qualification.
v. Reference standard
Reference standards can be either primary or secondary (sometimes called working standards).
The primary standards are authentic materials with very high purity. The pharmacopeias and regulatory
agencies recognize primary standards as the official industry standards for particular tests.
Secondary reference standards are also substances of established quality and purity, usually prepared in-
house. The same core should be taken in preparing the secondary reference standard as is taken when
preparing the sample for the test.
The analyst should ensure that only the current and approved reference standards are used for testing. The
reference standard number must be recorded in the test record.
All quality control laboratories must have a set of published and approved specifications for each starting
material and finished product.
When calculating and checking results, the analyst should refer to the current specification to decide the
status of the sample. These specifications are often registered with the regulatory agency and cannot be
changed.
It is a GMP rule that staff are trained on the approved documents applicable to their work areas and must
sign to the effect that they understand the requirements.
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viii. Internal GMP audits
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Internal GMP audits or self-inspections are requirements under good laboratory practice (GLP). The purpose
of an internal audit is to independently check that the rules and documents established by the quality
assurance team are being followed.
Internal GMP audits also provide opportunities to improve procedures and practices in the factory.
Laboratory result out-of-specification events are a common occurrence in the quality control process. A
laboratory investigation is required before any repeat assays are conducted if a single assay result does not
meet the agreed specification.
The laboratory must determine, if possible, whether a laboratory error, sample, or batch failure is the cause
of the out-of-specification result.
Out of Specification
i. Sampling of materials
The sampling of starting materials and finished products is completely governed by GMP regulations. You
must document all sampling procedures and plans in use.
If wrong or insufficient samples are taken, or a poor sampling technique is used, any subsequent testing
may then give misleading results.
As a result, a good product may be rejected, or, much worse, a defective product may be released.
Testing of samples in the laboratory is a mandatory requirement under GMP regulations. Its effectiveness,
though, is limited because the entire batch cannot be tested, nor can the batch be tested for all types of
potential contamination.
In fact, quality control testing is limited to looking for defects after they have occurred, so it is not a QA
prevention system but rather a defect detection system.
Batches may not be released to the market if results do not conform to the approved specifications.
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GMP rules that are applied to the quality control laboratory are sometimes called G(Control)LP rules, or
G(C)LP. These G(C)LP rules are also checked during laboratory audits:
– Record or capture all generated raw data directly, promptly, and legibly.
– Archive records so that they are protected, secured, and easily retrievable.
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The laboratory quality manual and laboratory policies are top-level documents describing the overall
management and organization of the laboratory. These documents should reflect the requirements under
GMP rules.
When you develop laboratory quality policies, consider including the following Items in your policies.
– Conflict of interest, ethics, and reference standards.
– Maintained and deployed procedures for laboratory operations and tests based on referenced
methods for testing.
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– Employment of qualified and trained personnel.
Standard operating procedures (SOPs) provide more detailed and specific requirements for each laboratory
quality element.
For example, SOPs describe how to handle a sample, conduct an audit, release a result from the laboratory,
and manage a complaint. SOPs are generally not specific to test methods.
Following are some common key SOPs for quality control Laboratories. QC staff should be familiar with the
following key SOPs:
– Training programs
Test methods provide specific stepwise directions on how to properly execute a test procedure in a
standardized manner.
A test method is specific to analysis and for instrumental techniques such as HPLC. Specifications generally
accompany test methods and provide pass/fail criteria and acceptance criteria for a test method, such as
system suitability or control limits.
Sample and reagent preparation sheets are used to document the instructions for preparing laboratory
solutions, standards, and working reagents.
Usually, these sheets are linked to specific test methods. Equally important are the instructions for
calibrating standard solutions.
v. Laboratory records
Testing records include quality control laboratory analyst notebooks, specific testing sheets, analytical
printouts, electronic records such as chromatographs, and ancillary records that support the laboratory’s
compliance.
Ancillary records would include calibration reports, training records, and monitoring of the environment.
vi. Specifications ←
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Specifications are documented for starting materials, in-process products, and finished products. These
specifications are submitted to the regulatory authorities when products are first registered.
If specifications need to be altered for whatever reason, approval must be sought from the government
regulators.
The finished product is required to meet the specifications throughout the full shelf life under the approved
storage condition.
A critical part of the quality control process is ensuring the reliability of results.
One way to ensure that the results are error-free is to conduct a second check of calculations and raw data.
This check should be independent, that is, done by a different analyst or supervisor.
Observations, data, and calculations shall be recorded when they are made and identifiable to the specific
task.
When mistakes occur in records, each mistake shall be crossed out, not erased, made illegible, or deleted,
and the correct value entered alongside.
All such alterations to records shall be signed or Initialled by the person making the correction. In the case of
records stored electronically, equivalent measures shall be taken to avoid loss or change of original data.
Pharmacopoeias are legal standards for the quality of products and materials. They specify the quality attributes
of products and materials in “monographs” and provide information on how tests should be conducted. ←
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i. Starting materials specification
In the pharmaceutical industry, the requirements for starting materials must be well-defined and
documented to ensure that you get the material specified or ordered and that there are no mix-ups.
Starting materials are defined by a standard name, the supplier’s/ manufacturer’s code, and a unique item
code.
– Any precautions
In the pharmaceutical industry, specifications for intermediate and bulk products should be available if
these are received or dispatched or if data obtained from tests on intermediate or bulk products are used
for the evaluation of the finished product or further processing.
The specifications should be similar to specifications for starting materials or for finished products, as
appropriate.
In the pharmaceutical industry, the requirements for pre-printed packaging materials must be well-defined
and documented to ensure that you get the items you specified or ordered and that there are no mix-ups.
You should include the following items in the packaging materials specifications:
– Acceptance criteria
– Storage conditions
– Any precautions
You should include the following items in the finished product specifications:
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– Sampling instructions
– Designated name
– Package details
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– Accuracy (difference between the average results and the “true” value)
– Selectivity (ability of the method to measure the analyte in the presence of interfering compounds)
– Linearity and range (over what range the method measures the analyte in direct proportion)
If a test method is not validated, it is difficult to be assured that the results are reliable.
GMP requires that all critical steps of manufacture are reliable or validated. This naturally includes laboratory test
methods.
Pharmaceutical sampling procedures are carried out during and at each major processing step during
manufacturing to ensure the highest quality is attained.
The purpose of testing samples is to make some inference about the lot from which the sample is drawn:
i. Sampling limitations
No matter how well or how often QC testing is conducted, there is always some risk that defects are not detected
in the lot.
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This means that a defective product could be released even though it passed all the tests. If one wanted to be
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100% sure that a batch does not contain any defects, every unit of the batch would have to be tested. Since this is
not practical, you have to accept some risks.
Despite these limitations, GMP regulations require companies to conduct quality control tests routinely. However,
when you properly follow GMP regulations during manufacture and packaging, it will help prevent defects from
occurring in the first place, which reduces the company’s reliance on quality control testing.
Sampling plans decide which lots of products to accept and release, and which lots to reject and either rework or
discard.
Ideally, a sampling plan should reject all “bad” lots while accepting all “good” lots. However, because the sampling
plan bases its decision on a sample of the lot and not the entire lot, there Is always a chance of making an
Incorrect decision.
This is termed the sampling risk. If a good lot is rejected incorrectly, this is called the supplier’s risk. Conversely, if a
poor lot Is accepted Incorrectly, this is called the consumer’s risk. Sampling plans generally try to set these risks
between 5% and 10%.
Naturally, the way the sample is selected has a big impact on the level of risk.
Corrective actions are required to eliminate the causes of an existing nonconformity, defect, or other undesirable
situation. Corrective actions are taken to fix a defect on hand.
On the other hand, preventive actions are implemented to prevent potential non-conformances in the future.
Preventive action is taken to fix the cause of a problem before it can happen. The future risk mitigation measures
are clear examples of preventive action.
Neither the FDA CFR 211 regulations nor international GMP standards specifically mandate CAPA systems as part
of the quality assurance system. However, they are implied and expected. ICH Q10 makes this requirement more
explicit.
Your organization must take action to eliminate the cause of nonconformities in order to prevent
recurrence. Corrective actions should be appropriate to the effects of the nonconformities encountered.
According to ISO 13485, you should prepare a documented procedure to define corrective action
requirements for:
– Evaluating the need for action to ensure that nonconformities do not recur,
You should determine action to eliminate the causes of potential nonconformities in order to prevent their
occurrence. Preventive actions should be appropriate to the effects of the potential problems.
As per ISO 13485, you should establish a documented procedure to define requirements for preventive
actions.
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– Records of the results of any investigations and of action taken and
The register provides a list of CAPA events and their current status. From the register, Supervisors can tell
which CAPA events are the most common and what stage they are at in being resolved. The register will also
be of interest to government auditors.
The best practice of CAP management should have the following features:
– A system for identifying when a CAPA closeout has not been met
The CAPA system can be broken down into four distinct phases, each of which requires different actions,
different outcomes, and probably different responsibilities.
For a detailed explanation you can check the article Six Step Procedure for corrective and preventive action.
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– External events or marketplace feedback such as complaints, adverse events, or service reports.
CAPAs can also originate from opportunities to improve any of the above.
One of the key tools for qualifying for a CAPA is risk assessment. Generally, applying risk assessment to an
issue will answer the question: “Does this incident merit a further investigation and a CAPA?”
If a CAPA is raised, it should be formally documented using a CAPA form and assigned a unique tracking ←
number. Responsibility is then assigned for conducting an investigation and root cause analysis. There are
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no particular rules regarding who should assume responsibility, but often, it is the group or person that
knows most about the problem or will derive benefit from its resolution.
This phase is about ensuring that there is a clear CAPA action plan based on the investigation and root cause
analysis in the previous phase.
The plan should be approved, actions to be taken should be set out, responsibilities assigned, and target
completion or progress review dates nominated for particularly large CAPAs, a formal project plan would be
useful.
The CAPA plan should be approved by the quality representative and the area management before
implementation. The plan should also be linked to change controls where they apply.
The last phase of a CAPA is to implement the approved plan and track its progress against agreed dates.
Once a CAPA plan is implemented, it is necessary to verify that it has been effective by monitoring the
Impact of the actions. The verification could be immediate or delayed until the CAPA impact becomes
evident. It is usual to keep the CAPA in “open” status during the monitoring phase until it is formally closed.
Conclusion
Since no one can create a system that can eliminate all unknown defects from a product, we must rely on quality
control process to guarantee product quality and safety.
The main objective of quality control is to check the quality of a batch as it was manufactured. The ideal ways of
implanting quality control tests are at the starting, middle, and end of the manufacturing process. Sometimes, you
have to implement 100% quality control checks, especially in those circumstances where the manufacturing
process isn’t stable, or the product is too sensitive to environmental factors.
Quality control processes are complex. To guarantee the operational success of a quality control laboratory, you
have to create high-level manuals and policies, standard operating procedures, validated test methods, use
qualified instruments, and train your analysts at a minimum.
You have to build a process to check the test results against predetermined parameters, also called specifications.
There are specifications for starting materials, packaging materials, intermediate, and finished products.
If, at any time, the laboratory test results fall outside of those specifications, you should investigate the incident as
out-of-specification, identify the root cause, and implement corrective and preventive actions.
There are strict rules and requirements from the regulatory authorities on how the quality control processes
should be established. Generally, they are called Good Laboratory Practices. You must always ensure that you are
complying with those requirements through periodic audits.
Quality is everyone’s responsibility, and it should pervade every aspect of pharmaceutical manufacture and
packaging. Quality should not be tested into products; instead, it must be built in at each step of manufacture.
Quality manifests itself not only in obvious ways, such as during actual processing steps, but also in diverse areas,
such as vendor assurance, personnel training, internal audits, change management, release for supply, and QC
sampling.
Pharmaceutical manufacturers must integrate the key functions of the quality control process. The primary
objective of this is to check for defects as they have occurred.
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Kazi Hasan
Kazi is a seasoned pharmaceutical industry professional with over 20 years of experience specializing
in production operations, quality management, and process validation.
Kazi has worked with several global pharmaceutical companies to streamline production processes,
ensure product quality, and validate operations complying with international regulatory standards and
best practices.
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