pharma Tag

Revision of Chapter 4 – Documentation

Chapter 4 has been revised to underline the importance of documentation in GMP compliance and incorporate support for new technologies, hybrid solutions, and new services in documentation management. Risk management principles are now focused and integrated into the data governance system to ensure the accuracy, integrity, availability, and legibility of documents in all types of formats (paper, digital, or hybrid).  The guideline also clarifies the requirements for managing electronic records, signatures, and data integrity, ensuring consistency with the concurrent revision of Annex 11.

Revision of Annex 11 – Computerised Systems

The revision of Annex 11 introduces stricter requirements for the life cycle management of computerized systems, requiring the full application of Quality Risk Management principles during all steps. The updated provisions consolidate the obligations relating to the definition and ongoing maintenance of system requirements and the oversight of suppliers and external service providers. Furthermore, the controls relating to data integrity, audit trails, electronic signatures, and system security have also been tightened.

New Annex 22 – Artificial Intelligence

The new annex about Artificial Intelligence sets out requirements for the use of AI and machine learning in the manufacturing of active substances and medicinal products and defines requirements for the selection, training and validation of AI models. Aspects related to defining the intended use of the model, defining performance metrics, the quality of model training data, and the management and processing of test data have been explored in depth. The document also provides for continuous oversight of AI systems, including change control, model performance monitoring, and human review procedures.

Taken together, these three documents aim to provide a comprehensive and robust framework that supports the implementation of information technology in pharmaceutical manufacturing, while maintaining product quality and patient safety.

SOURCES:

https://health.ec.europa.eu/consultations/stakeholders-consultation-eudralex-volume-4-good-manufacturing-practice-guidelines-chapter-4-annex_en

1079.5 Transportation Lane Temperature Mapping and Qualification

The General Chapters—Packaging and Distribution Expert Committee has proposed a new chapter addressing the evaluation and qualification of transportation routes to ensure appropriate storage conditions during distribution.

The transportation environment is critical to product preservation and is often outside the direct control of the shipper, including manufacturers, distributors, freight forwarders, and healthcare providers.

It is well known that transport presents specific risks due to the environmental variability to which the products may be exposed and the limited control through the distribution network.

This chapter outlines best practices for temperature lane mapping and transport route qualification to ensure the integrity of pharmaceutical products.

This new chapter formalizes lane-level risk management in pharmaceutical distribution and will have a direct impact on logistics service providers, distributors and manufacturers relying on ambient or temperature-controlled transport, requiring more rigorous oversight and documented evidence of distribution integrity.

Companies must establish mapping protocols, qualify critical routes, and integrate lane performance into their GDP and change control systems to ensure smooth operations.

Also published in this issue of PF is a Stimuli article, Transportation Lane Temperature Mapping and Qualification—Risk Identification and Evaluation, that provides additional background and context for the development of this chapter.

 

SOURCES:

The complete draft is available on the official USP website. Public comments are accepted until 30 November 2025

The European Pharmacopoeia has revised chapter 3.2.1. “Glass containers for pharmaceutical use”.

The revision was issued to clarify the purpose of tests A, B, and C used to define the type of glass and characterize the hydrolytic resistance of the glass. The presentation of the information (Table 3.2.1-1) has been modified to add further details about each test and its respective purpose.

The second update concerns the approach used to determine the maximum transmission limit for colored glass containers. Since the light protection or light transmission of a coloured glass depends on the wall thickness of the containers, it was decided to base the determination of the maximum spectral transmission and related specifications on the wall thickness insteadof the volume and closure system of the containers. The proposed limits take into account detailed data on containers available on the European market.

SOURCES:

https://www.edqm.eu/en/-/ph.-eur.-publishes-revised-general-chapter-3.2.1.-glass-containers-for-pharmaceutical-use-in-pharmeuropa-37.3

EMA has published a Questions and Answers document (EMA/129980/2025) on how third party audit(s) should be reflected in part C of the QP Declaration with two new questions (Questions 3 and 9 under EU GMP guide part II: Basic requirements for active substances used as starting materials: GMP compliance for active substances).

  • Is an audit performed by a third party acceptable?
  • What are the expectations for the content of written final assessment of third-party audit reports?

The answers summarise quite clearly what is currently required and what a Qualified Person must be aware of, when accepting audit reports from external auditors, including the requirement of the written final assessment document and approval of third-party audit reports.

These Q&A’s were drafted and adopted by the GMDP Inspectors Working Group.

SOURCES:

https://www.ema.europa.eu/en/documents/other/questions-answers-how-should-third-party-audits-be-reflected-part-c-qp-declaration_en.pdf

The European Pharmacopoeia (Ph. Eur.) is seeking stakeholder feedback on the revised general chapter 5.1.6. “Alternative methods for control of microbiological quality”, which was published in the quarterly edition of Pharmeuropa 37.2 for comment and public consultation until the end of June 2025.

The aim of this chapter is to facilitate the implementation of rapid microbiological methods (RMM), an innovative and versatile approach in the field of microbiology.

The revision of this chapter is part of the overall efforts of the Ph. Eur. Commission (EPC) to support and accelerate the introduction of alternative RMMs, especially beneficial for products with a short shelf life.

The new revision clarifies the responsibilities of suppliers and users and includes new information to help users optimise their implementation strategies, taking advantage of the suitable tests already performed and evaluating different development activities simultaneously. The subsection on primary validation has also been updated and clarified, while the guidance on product-specific validation has undergone extensive revision with the addition of several examples.

The 54 drafts published in Pharmeuropa 37.2 are listed in the Newsroom “Pharmeuropa 37.2 just released”, which invites experts, users and interested parties to leave their comments

 

SOURCES:

https://www.edqm.eu/en/-/public-consultation-on-revised-general-chapter-5.1.6.-alternative-methods-for-control-of-microbiological-quality-in-pharmeuropa-37.2

On 11 April 2025, the ICH Q1 Draft Guideline “Stability Testing of Drug Substances and Drug Products” was published and is now open for public comment. Comments are possible until the end of July 2025, with some exceptions specifically indicated on the ICH website.

This new version is intended to merge and replace all the pre-existing individual ICH guidelines (ICH Q1A-Q1F and ICH Q5C) on the topic of stabilities. It will apply to active substances and finished drug products and takes into account new scientific and risk-based approaches and technologies.
This guideline will therefore incorporate:

  • Stability testing of new drug substances and drug products (ICH Q1A)
  • Stability testing: photostability testing of new drug substances and products (ICH Q1B)
  • Stability testing: requirements for new dosage forms (ICH Q1C)
  • Bracketing and matrixing designs for stability testing of new drug substances and products (ICH Q1D)
  • Evaluation for stability data (ICH Q1E)
  • Stability data package for registration applications in Climatic Zones III and IV (ICH Q1F)

SOURCES:

https://www.ema.europa.eu/en/documents/scientific-guideline/draft-ich-q1-guideline-stability-testing-drug-substances-drug-products-step-2b_en.pdf

The guideline “Additional guidance on the assessment on the risk assessment for presence of N-nitrosamines in APIs”, first prepared in February 2020 by the APIC Nitrosamines Task Force on behalf of the Active Pharmaceutical Ingredient Committee (APIC), has now been revised by a subgroup of the APIC Nitrosamines Task Force to reflect latest guidance and recommended practice and recently published on the APIC website. The document is now called “Nitrosamine Risk Management: Guidance for API Manufacturers” and has been extensively updated.

Among the new features introduced, a separate chapter is dedicated to the incorporation of nitrosamine risk management into the quality management system.

 

SOURCES:

https://apic.cefic.org/wp-content/uploads/2025/05/APIC-Nitrosamines-Risk-management_Guidance-for-API-Manufacturers_Final.pdf

Revision 22 of the Q&A document “Questions and answers for marketing authorisation holders/applicants on the CHMP Opinion for the Article 5(3) of Regulation (EC) No 726/2004 referral on nitrosamine impurities in human medicinal products” has been published on the EMA website.

The additions and changes made mainly concern the questions 10 and 22.

Updates to Q&A 10 to clarify the applicable acceptable intake (AI) limit to different administration routes and accepted in vivo study type.

Update of Q&A 22 to highlight expectations for the submission of changes in shelf-life and storage conditions required to comply with the interim limit during CAPA implementation.

 

SOURCES:

https://www.ema.europa.eu/en/human-regulatory-overview/post-authorisation/pharmacovigilance-post-authorisation/referral-procedures-human-medicines/nitrosamine-impurities/nitrosamine-impurities-guidance-marketing-authorisation-holders

In January 2025, the Task Force “Data Integrity” of the Quality Group of APIC (CEFIC), has published the version 2.0 of the document “Data Integrity Frequently Asked Questions (FAQ)“.

This document contains a collection of frequently asked questions that have been submitted by the industry to the Data Integrity taskforce. Since this is a living document, it is updated as new questions are posed to the group.

Updated questions are written in red: the new questions and answers can be found in the “Password management” and “Access management” sections.

  1. Password management

Q1: When I logged into a system, do I need to re-authenticate myself for every data entry?

A: No, it depends upon the criticality of the data/action. This criticality should be based upon process mapping and a risk assessment as explained in the guide. Criticality of the data and/or responsibility associated with the action should be taken into account when evaluating electronic signature requirements.

Q2: What are the requirements for e-signature components? (This question in version 1 of the FAQ was worded differently whereas it has now been revised as above)

A: This practice is described in 21CFR11, chapter 11.200 “e-signature and components”:

(i) When an individual executes a series of signings during a single, continuous period of controlled system access, the first signing shall be executed using all electronic signature components (= user ID and password or biometrics); subsequent signings shall be executed using at least one electronic signature component that is only executable by, and designed to be used only by, the individual.

(ii) When an individual executes one or more signings not performed during a single, continuous period of controlled system access, each signing shall be executed using all of the electronic signature components

  1. Access management

Q2: Can we extend the time of a user session before this is automatically locked for inactivity because of a HSE (health-safety-environment) concern?

A: The inactive time of a user session should be managed by the user locking their computer station when they move away for an extend period of time to prevent unauthorised actions been taken by other persons. The automatic lock is a security measure. A reasonable amount of time should be supported by a risk assessment. This type of HSE concern should be managed independently of the GXP system with an emergency stop button as an example. If this is approach is not feasible, the computerized system should be designed as such that a fast intervention is possible. It is best practice for a system like a DCS to be configured in such a way that the screen does not completely goes into operating system lock and actions can be taken by clicking on the valve or object and entering a password to confirm the action.

 

SOURCES:

https://apic.cefic.org/wp-content/uploads/2025/01/FAQ-DI-APIC-TF-Version-2-Jan-25-1.pdf

The Version 17 of the “How to do” document – Interpretation of ICH Q7 Guide and “Review form” for APIs was finalized last November and published on the Active Pharmaceutical Ingredients Committee (APIC) website in early 2025.

The document aims to facilitate the implementation of the ICH Q7 guideline and provides recommendations for its interpretation.

In this version, additions and updates have been made in the following chapters:

  • Chapter 2 Quality Management
    • the changes were made in the subsections 2.1 Principles (10, 2.12, 2.14) and 2.2 Responsibilities of the Quality Unit(s) (2.21).
  • Chapter 5 Process Equipment
    • additions and innovations have been made in subsections: 5.2 Equipment Maintenance and Cleaning, 5.3 Calibration, and 5.4 Computerized Systems
  • Chapter 13 Change Control
    • updates concern items 10, 13.11, 13.12, 13.13, 13.14, 13.15.
  • Chapter 21 ICH Q7 Q&A “how to do” attachment (Questions and Answers linked to the respective sections of ICH Q7)
    • some Questions & Answers in Chapter 5 “Process Equipment – Cleaning” have been more clearly interpreted and aligned with the newly published guidelines.

SOURCE:

https://apic.cefic.org/wp-content/uploads/2025/01/ICH-Q7-How-To-Do-version17_cleandocument_241122.pdf