Thousands of drugs at risk if no Brexit deal, European pharmaceutical companies warn

Brexit threatens the free flow of these goods, given stringent medicine regulations that may require the retesting of drugs shipped across borders in the absence of an agreed trading arrangement.

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Supplies of thousands of medicines are at risk of disruption if Britain leaves the European Union without a trade deal, European pharmaceutical companies warned on Thursday. More than 2,600 drugs have some stage of manufacture in Britain and 45 million patient packs are supplied from the UK to other European countries each month, while another 37 million flow in the opposite direction. Brexit threatens the free flow of these goods, given stringent medicine regulations that may require the retesting of drugs shipped across borders in the absence of an agreed trading arrangement.

The European Federation of Pharmaceutical Industries and Associations (Efpia) said a survey of its members showed 45 percent of companies expected trade delays if Britain and Europe fell back onto World Trade Organization rules after Brexit. Drugmakers also face an additional hurdle when it comes to licensing their products, since more than 12,000 medicines will require a separate UK licence in order for them to be prescribed. “For life-saving and life-improving medicines, the EU and UK cannot afford to wait any longer to ensure that the necessary cooperation on medicines is in place from the day the UK leaves the EU,” said Efpia Director General Nathalie Moll.

Pharmaceutical companies have insisted since last year’s Brexit referendum that a comprehensive agreement is needed to ensure maximum alignment between EU and British pharmaceutical regulations. But with the clock ticking down to Brexit in March 2019 with no sign yet that a trade deal will be concluded, many companies are now starting to draw up plans to protect drug supply chains, including building extra testing centres in Europe.

 

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Six Systems Approach to Pharmaceutical cGMP Regulations

Six Systems Approach to Pharmaceutical cGMP Regulations.

The FDA has enacted several pharmaceutical cGMP regulations. These are key concepts that are critical to quality systems. Some of the concepts by which the FDA and other regulatory bodies ensure cGMP regulations are Quality, Quality by Design (QbD) and product development, Quality Risk Management, Corrective and Preventive Action (CAPA), Change Control, and the Six Systems Approach.

Of these, the six-system inspection approach is a systems-based approach to cGMP and is aimed at ensuring a robust quality system model for pharmaceutical products.

It consists of the following:

Quality System

• Facilities System
• Equipment System
• Materials System
• Production System
• Packaging & Labeling System

Quality system is the fulcrum

It needs to be borne in mind that the whole system centers round the organization’s quality system. The quality system is the pivot around which the systems approach revolves. It is the core and the very foundation for the manufacturing systems that are linked and function within it. 

The FDA does not consider the quality system as different or separate from the five elements. In this sense, it the quality system model may be considered the root from which the five elements branch out.

In other words, the five manufacturing systems integrate themselves them into the respective and appropriate sections of the model. The order of interplay and interdependence may vary slightly from one organization to another, but to those in the knowhow of the six-system inspection approach; the rationale by which the inter-relationship plays out is quite readily apparent.

State of control –the crux of the matter

The entire purpose of having a systems approach in which the systems are independent, yet integrate into each other seamlessly is that having a systems-based inspection compliance program ensures that the organization is equipped with the ability to assess whether each of the systems is in a state of control.

 References:

http://www.fda.gov/downloads/Drugs/…/Guidances/UCM070337.pdf

Thanks & Best Regards,
John Robinson
GlobalCompliancePanel
161 Mission Falls Lane, Suite 216, Fremont, CA 94539, USA.
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Email: john.robinson@globalcompliancepanel.com