What is CGMP?
CGMP is Current Good Manufacturing Practice regulations enforced by the FDA and other regulatory authorities. CGMP standards provide for systems that assure the most updated and proper design, monitoring, and control of manufacturing processes (supply chain included) and facilities. The CGMP regulations reassure the identity, purity, quality of consistently manufactured goods by requiring that manufacturers adequately control operations.
CGMP Requirements
The CGMP
requirements have been established to be flexible (because this also is a management
system standard) to allow each manufacturer to decide individually how to best
implement the necessary controls by using scientific and technological design,
processing methods, and testing procedures. The flexibility in these
regulations adheres to companies to implement advanced technologies/ innovative
approaches to achieve higher quality making continual improvement. Accordingly,
the "C" in CGMP stands for "current," requiring companies
to use current(up-to-date)technologies and systems that comply with the
regulations. Systems and equipment and machinery that may have been
"up-to-date" to prevent contamination and errors 5 or 10 years ago
maybe less than adequate by today's standards.
Why CGMPs are
important?
A consumer or the
end-user usually cannot detect (through smell, touch, or sight) that a
particular product is either safe or if it will work. While CGMPs require
testing, testing alone is not enough to ensure quality. In most instances,
testing is done on a sample of a batch (for example, a drug manufacturer may
test 200 tablets from a batch that contains 2 million tablets).
Therefore, products
must be under conditions and practices required by the CGMP/FDA/WHO regulations
wherever required to assure that quality. Technologically updated and modern
facilities that are in good condition, equipment that is properly maintained,
qualified, and calibrated, employees who are competent, qualified, and
fully-trained, are a few criteria how CGMP requirements help in assuring the
safety and purity of drug products.
FDA generally
doesn’t inspect manufacturing facilities. Certification Bodies that have
expertise in auditing, inspection GMP facilities worldwide, generally do that,
including for facilities that manufacture active ingredients and the finished
product. Inspections follow a standardized approach and are conducted by highly
trained and qualified staff. Certification Bodies also relies upon reports of
potentially defective drug products from the public and the industry. They also
often use these reports to identify sites for which an inspection or
investigation is needed.
Without CGMPs, are
pharma/drug products/medical products safe for use?
For drug/pharma
manufacturers, CGMP is mandatory.
If a company is not
complying with CGMP regulations, it is considered “adulterated” under the law
of land. This kind of adulteration means that the drug was not manufactured
under conditions with CGMP, prescribed by legal and regulatory bodies
If a consumer takes
medicines violating the CGMPs regulations then FDA usually advises the
consumers not to interrupt their drug therapy, which might have serious
implications for their health. Consumers should then, seek advice from
professionals before stopping or changing medications.
Regulatory actions
against companies with poor CGMPs by the Government, are often intended to
prevent the possibility of unsafe and/or ineffective drugs. In rare cases, the FDA
or the Government regulatory action is often intended to stop the distribution
or manufacturing of the violated product. The impact of CGMP failure depends on
the nature of those violations and the specific drugs involved. A drug
manufactured in violation of CGMP may If the drug still meets its labelled
specifications but a violation of CGMPs regulation then the drug is unsafe or
ineffective could be minimal.
Thus, FDA’s advice
is more often very specific to the circumstances, and health care professionals
are best able to balance risks and benefits (as relevant) and make the right the decision for their patients?
What can FDA or
Government do safeguard the public when there is a failure in CGMPs?
If the company
fails to meet CGMPs results in the distribution of a drug, for example, it has
a too less active ingredient, the company may subsequently recall back that
product. Removing the drug from the market protects the public from any health
issues. While FDA/GOVERNMENT/GOVERNMENT AGENCY-BODY/REGULATORY BODY cannot
force a company to recall a drug, companies usually recall voluntarily or at
FDA/GOVERNMENT/GOVERNMENT AGENCY-BODY/REGULATORY BODY’s request. If a company
refuses to recall a drug, FDA/GOVERNMENT/GOVERNMENT AGENCY-BODY/REGULATORY BODY
might warn the public and can seize the drug.
CGMP violations can
be addressed or sued to court by FDA/GOVERNMENT/GOVERNMENT
AGENCY-BODY/REGULATORY BODY even where there is no direct evidence of a defect
affecting the drug’s performance. When FDA/GOVERNMENT/GOVERNMENT
AGENCY-BODY/REGULATORY BODY brings a seizure case, the agency asks the court
for an order that allows federal officials to take possession of “adulterated”
drugs. When FDA/GOVERNMENT/GOVERNMENT AGENCY-BODY/REGULATORY BODY brings an
injunction case, FDA/GOVERNMENT/GOVERNMENT AGENCY-BODY/REGULATORY BODY asks the
court to order a company to stop violating CGMPs. Both seizure and injunction
cases often lead to court orders that require companies to take many steps to
correct CGMP violations, which may include repairing facilities and equipment,
improving sanitation and cleanliness, performing additional testing to verify
quality, and improving employee training. FDA/GOVERNMENT/GOVERNMENT
AGENCY-BODY/REGULATORY BODY can also bring criminal cases because of CGMP
violations, seeking fines and jail time.
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