GMP -Personnel requirements – PST05207 Quality Assurance of Pharmaceutical Products

NTA Level 5 • Semester 2 • PST05207

GMP -Personnel requirements

Quality Assurance of Pharmaceutical Products • Source Session/Topic 3
Full source-text version: all educational wording from the extracted learning source is retained; only presenter/tutor metadata and web-layout noise are removed, while formatting is improved for readability.

Session 3: GMP -Personnel requirements

Total Session Time: 120 minutes

Prerequisites

• None

Learning Tasks

By the end of this session students are expected to be able to:

• List general possible issues related to personnel in GMP
• List general principles related to personnel in GMP
• Explain requirements for key personnel in GMP
• Review the training of personnel in GMP

Resources Needed:

• Flip charts, marker pens, and masking tape
• Black/white board and chalk/whiteboard markers
• Pointer
• LCD Projector and computer.

SESSION OVERVIEW

Activity/

Step Time Content

Method

1 05 minutes Presentation Introduction, Learning Tasks

35 minutes Presentation General Possible Issues Related to Personnel

2

Buzzing in GMP

30 minutes General Principles Related to Personnel in

3 Presentation

GMP

30 minutes Presentation

4 Requirements for Key Personnel in GMP

Brainstorming

5 10 minutes Presentation Reviewing the Training for Personnel in GMP

6 05 minutes Presentation Key Points

7 05 minutes Presentation Evaluation

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

SESSION CONTENTS

STEP 1: Presentation of Session Title and Learning Tasks (5 minutes)

READ or ASK students to read the learning tasks and clarify

ASK students if they have any questions before continuing.

STEP 2: General Possible Issues Related to Personnel in GMP ( 35

minutes)

Activity: Buzzing (5 minutes)

ASK students to pair up and buzz on the following question for 2 minutes

• What are general possible issues related to personnel in GMP?

ALLOW few pairs to respond and let other pairs to add on points not mentioned

WRITE their response on the flip chart/board

CLARIFY and SUMMARIZE by using the content below

• The general possible issues related to personnel in GMP are:

o In a company the issues will be around a lack of skills and resources to comply with

all the requirements of GMP:

 Limited staff numbers may mean that people are under pressure to perform. They

may be trying to do too much. There may be a lack of deputies during times of

illness or holidays.

 Recruited staff may have inadequate qualifications.

 Recruited staff may have inadequate experience or experience in an inappropriate

area. Sometimes the owner recruits relatives who are inadequately qualified or

experienced.

 The owner may interfere with quality decisions, particularly if orders are required

urgently or are very valuable. Senior staff may have difficulty in combating this,

since it may cost them their jobs.

 Smaller companies may have no means to develop training materials to educate

their staff in the requirements of GMP. They do not become members of the local

manufacturers‟ association because of cost. They do not then have access to

training programmes that are available through the association.

 Subsidiaries of multinational companies may claim that company procedures or

standards take precedence over local legislation. If this is claimed, it will be most

unusual since all multinationals require local companies to conform first to local

legislation. It will be worth exploring with the company what benefits are obtained

by not conforming to local legislation.

 Large organizations often move people around through promotion, training,

recruitment or relocation. In so doing they can lose sight of the requirements of

GMP. Managers can be promoted into positions for which they are not qualified or

experienced.

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

 Companies may not keep adequate training records even though people are

apparently undergoing training.

 As with small companies, large companies may have personnel policies that

penalize people. The problem is that if people are not going to be paid when sick

or injured, they may work on under circumstances that create a risk to the product.

STEP 3: General Principles Related to Personnel in GMP ( 30 minutes)

The following are principles related to personnel in GMP:

• For successful and good quality pharmaceutical production, it is essential to have people

with sufficient knowledge and experience to undertake the work. They must have the

authority and the means to do that work, and there must be enough of them available to

carry out tasks effectively.

• It is most important that the people that are recruited are selected from a group that can

meet the requirements.

• It is not recommended to recruit people to work in manufacturing areas if they are unable

to read the instructions for their safety and for product quality. A medical examination

should be included during the recruitment processes. Operators working with cytotoxic

products may need blood tests at the time of recruitment and at six monthly intervals

thereafter.

• Operators who will work on visual inspection processes should also undertake an eye test

at the time of recruitment with a regular check on a periodic basis afterwards.

• A major and most common problem is that of insufficient people available to do the

work. It is of little value having just one person well qualified and experienced, with no

backup staff. What then happens in the case of sickness or holiday? This can be a very

difficult area, and one which is harder for smaller companies than a multinational

company or similar.

• Another issue that often surfaces is the employment of a well-qualified, but inexperienced

person to manage, for example, quality. An illustration of this is the recruitment by the

owner of a small company of a relative — who is newly qualified, but completely

inexperienced to run a laboratory or manufacturing area.

• The duties incumbent upon any one individual should not be so extensive that he/she

cannot cope, resulting in a risk to quality of the product.

• Staff must have a clear job description which tells them and the rest of the company what

their role is, what their responsibilities are and what authority they have to carry out their

tasks. The company should also have a written organization chart. The combination of

organization chart and written job descriptions enables the company to see quickly

whether there are any gaps or whether there are any areas of overlap, owing to too many

people being involved. The organization chart should make clear and ensure the

independence of QA/QC from production.

• Personnel involved in QA/QC must have the authority to carry out their responsibilities.

This is very easy to say and sometimes not so easy to ensure. Problems can emerge in

every size of company, from small private companies to very large multinational

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

enterprises. They arise because of a combination of human interactions, and the pressures

placed on people by the business considerations

• All personnel involved with materials and products should receive GMP training. This

training should commence upon recruitment and continue throughout employment. The

training should be appropriate to their needs and position within the company, and should

include training in hygiene standards.

• Personnel policies should be designed to encourage people to support the development

and maintenance of high quality standards in all work performed.

• The company should prevent people who have not been properly trained from entering

any production, storage or quality control area without strict supervision. For example: it

should not be the case that people from accounts are allowed to walk through the factory

to get to the warehouse to pick up or deliver invoices. Access to all other areas of the

company should be organized so that no entry to production, storage or laboratory areas is

necessary (see Premises).

STEP 4: Requirements for Key Personnel in GMP (30 minutes)

Activity: Brainstorming (5 minutes)

ASK students to brainstorm on the following question:

• What are requirements for key personnel in GMP?

ALLOW few students to respond

WRITE their responses on the flip chart/ board

CLARIFY and SUMMARISE by using the content below

• Key personnel include the following

o The heads of production,

o Quality control personnel

o Sales and distribution personnel

o Authorized person who releases product for sale

• Normally they should all be full-time positions.
• The heads of production and quality control should not report to one another (although they may

both report to a technical director) but may share certain responsibilities.

• In large organizations, it may be necessary to delegate some of the functions; however, the

responsibility cannot be delegated.

• The principle is that there must be independence of quality control from production.
• These key personnel must have the education and experience which is appropriate to their positions.
• Heads of Production and Quality Control should be independent of each other
• Should possess appropriate qualifications Scientific education such as:

 chemistry or biochemistry

 chemical engineering

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

 microbiology

 pharmaceutical sciences and technology

 pharmacology and toxicology

 physiology; or

 other related science subjects relevant to the responsibilities to be undertaken

• The WHO GMP text part one, section 9.7 refers to some of the acceptable qualifications of key

personnel and it goes into a lot of detail.

• Key personnel should first of all have the educational background specified by local legislation

and with the requirements set out in company policy. This will include a combination of

chemistry, biochemistry, chemical engineering, microbiology, pharmaceutical sciences and

technology, pharmacology and toxicology, physiology or other related science subjects relevant to

the responsibilities to be undertaken.

• In particular, the GMP text talks about gaining experience not in a haphazard way, but under

specific guidance of an expert. This is in order to equip personnel with an ability to take difficult

decisions in a professional and scientific way, and to resolve the problems encountered in

manufacturing and quality control.

• It is clear, therefore, that we are talking about professionals who have had a practical as well as an

academic training.

• They should also continue to have training in their area of expertise.
• There are others who play an important role in the operation of the factory, for example, engineers.

Engineers are crucial to the maintenance and operation of the facility and equipment, in particular,

for the processes of planned preventative maintenance and validation.

• Should possess appropriate experience

o Practical experience

o Manufacture and quality assurance

o Preparatory period under professional guidance sometimes needed

o Education and experience should enable personnel to take difficult decisions in an independent,

professional and scientific way resolve the problems encountered in manufacturing and QC

• Personnel should also possess appropriate experience including practical experience in the

manufacture and quality assurance of pharmaceutical products. It is common and recommended,

that there should be a preparatory period under professional guidance for new employees.

• Education and experience should enable personnel to take difficult decisions in an independent,

professional and scientific way, and to resolve the problems encountered in manufacturing and

QC.

STEP 5: Reviewing the Training for Personnel in GMP (10 minutes)

The following are the key points for reviewing training for personnel in GMP

• Training, in accordance with a written, approved programme
• All personnel whose duties take them into production areas; or Into control laboratories;

and For others whose activities could affect the quality of the product including technical,

maintenance and cleaning personnel

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

• Induction and continuing training

o On theory and practice of GMP and their duties

o Training records should be kept

o Practical effectiveness checked

o Training before undertaking any new task

• Specific training for staff in special areas, e.g. Where contamination is a hazard,

Including clean areas; or Areas where highly active, toxic, infectious, sensitizing materials

are handled

• The concept of QA should be fully discussed during training to facilitate proper

understanding to ensure its implementation

STEP 6: Key points (5 minutes)

• Personnel general requirements: Adequate number of personnel, All personnel should be

aware of GMP, personnel must receive training and have appropriate qualification

• Key personnel include: Authorized person , head of production and head of quality

control

STEP 7: Evaluation (5 minutes)

• What are general Personnel Requirements in GMP?
• Who are the key personnel as in accordance to GMP?
• What are general principles related to personnel in GMP?

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

References

Signore, A. A., & Jacobs, T. (2017). Good design practices for GMP pharmaceutical

facilities. Boca Raton, Fl.: CRC Press.

Lund, W. (2009). The pharmaceutical codex: Principles and practice of pharmaceutics. New

Delhi: CBS.

Aulton, M. E., & Taylor, K. (2018). Aulton s pharmaceutics: The design and manufacture of

medicines. Edinburgh: Elsevier.

Rawlins E.A, Editor: (1977) Bentley’s Textbook of Pharmaceutics, 8th Ed. Baillie're Tindall.

London

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PST 05207 Quality Assurance of Pharmaceutical Products NTA Level 5 Semester 2

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