Guidance for Industry 

 
Q10 Pharmaceutical 

Quality System 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
U.S. Department of Health and Human Services 

Food and Drug Administration 

Center for Drug Evaluation and Research (CDER) 

Center for Biologics Evaluation and Research (CBER) 

 
 
April 2009 

ICH 

 
 
   
Guidance for Industry 

 
 
Q10 Pharmaceutical 

Quality System 

 
 
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 http://www.fda.gov/cber/guidelines.htm.   

 
 
 
 
U.S. Department of Health and Human Services 

Food and Drug Administration 

Center for Drug Evaluation and Research (CDER) 

Center for Biologics Evaluation and Research (CBER) 

 
 
April 2009 

ICH 

   
TABLE OF CONTENTS 

 
I.	   INTRODUCTION (1, 1.1)................................................................................................ 1 
 
II.	   PHARMACEUTICAL QUALITY MANAGEMENT SYSTEM ................................. 2 
 
A. 	  Scope (1.2).......................................................................................................................................2
  
B. 	  Relationship of ICH Q10 to Regional GMP Requirements, ISO Standards,  

and ICH Q7 (1.3)............................................................................................................................3
  
C. 	  Relationship of ICH Q10 to Regulatory Approaches (1.4).........................................................3
  
D. 	  ICH Q10 Objectives (1.5)..............................................................................................................3
  
E. 	  Enablers: Knowledge Management and Quality Risk Management (1.6) ............................... 4 
 
F. 	  Design and Content Considerations (1.7) ....................................................................................4 
 
G.  	 Quality Manual (1.8)......................................................................................................................5
  
III.  	 MANAGEMENT RESPONSIBILITY (2)...................................................................... 5 
 
A. 	  Management Commitment (2.1)...................................................................................................5 
 
B. 	  Quality Policy (2.2).........................................................................................................................6
  
C.  	 Quality Planning (2.3)....................................................................................................................6
  
D.  	 Resource Management (2.4)..........................................................................................................7
  
E.  	 Internal Communication (2.5) ......................................................................................................7
  
F. 	  Management Review (2.6)............................................................................................................7
  
G.  	 Management of Outsourced Activities and Purchased Materials (2.7)....................................7
  
H.  	 Management of Change in Product Ownership (2.8).................................................................8 
 
IV. 	  CONTINUAL IMPROVEMENT OF PROCESS PERFORMANCE AND 

PRODUCT QUALITY (3) ............................................................................................... 8 
 
A. 	  Lifecycle Stage Goals (3.1) ............................................................................................................8
  
B. 	  Pharmaceutical Quality System Elements (3.2)..........................................................................9 
 
V. 	  CONTINUAL IMPROVEMENT OF THE PHARMACEUTICAL QUALITY 

SYSTEM (4) .................................................................................................................... 13 
 
A. 	  Management Review of the Pharmaceutical Quality System (4.1)..........................................13 
 
B. 	  Monitoring of Internal and External Factors That Can Have an Impacton the 

Pharmaceutical Quality System (4.2).........................................................................................13 
 
C. 	  Outcomes of Management Review and Monitoring (4.3).........................................................14
  
VI.   GLOSSARY (5)............................................................................................................... 15
  
Annex I: Potential Opportunities To Enhance Science- and Risk-Based Regulatory 

Approaches *............................................................................................................... 18 
 
Annex 2: Diagram of the ICH Q10 Pharmaceutical Quality System Model....................19
 
  i   
1
 
Guidance for Industry  
Q10 Pharmaceutical Quality System  

 
 
 
 
This guidance represents the Food and Drug Administration's (FDAs) current thinking on this topic.  It 
does not create or confer any rights for or on any  person and does not operate to bind FDA or the public.  
You can use an alternative approach if the approach satisfies the requirements of the applicable statutes 
and regulations.  If you want to discuss an alternative approach, contact the FDA staff responsible for 
implementing this guidance.  If you cannot identify the appropriate FDA staff, call the appropriate 
number listed on the title page of this guidance.  
 
 
 
 
I.  INTRODUCTION (1, 1.1)2  
 
This internationally harmonized guidance is intended to assist pharmaceutical manufacturers by 
describing a model for an effective quality management system for the pharmaceutical industry, 
referred to as the pharmaceutical quality system. Throughout this guidance, the term  
pharmaceutical quality system refers to the ICH Q10 model.  
 
ICH Q10 describes one comprehensive model for an effective pharmaceutical quality system that 
is based on International Organization for Standardization (ISO) quality concepts, includes 
applicable good manufacturing practice (GMP) regulations, and complements ICH Q8 
Pharmaceutical Development and ICH Q9 Quality Risk Management.3  ICH Q10 is a model 
for a pharmaceutical quality system that can be implemented throughout the different stages of a 
product lifecycle. Much of the content of ICH Q10 applicable to manufacturing sites is currently 
specified by regional GMP requirements. ICH Q10 is not intended to create any new 
expectations beyond current regulatory requirements. Consequently, the content of ICH Q10 that 
is additional to current regional GMP requirements is optional. 
 
                                                 
1  This guidance was developed within  the Expert Working Group (Quality) of  the International Conference on  
Harmonisation of Technical Requirements for Registration of Pharmaceuticals for Human Use (ICH) and has been  
subject to consultation by the  regulatory  parties, in accordance with the ICH process.  This document has been  
endorsed by the ICH Steering Committee at Step 4  of the ICH process, June  2008.  At  Step 4  of the process, the final  
draft is recommended for adoption to the regulatory  bodies of the European Union, Japan, and the United States. 
2 Arabic numbers reflect the organizational breakdown of the document endorsed  by the ICH Steering Committee at 
Step 4 of  the ICH process,  June 2008. 
 
3  These guidances are available on the Internet at  http://www.fda.gov/cder/guidance/index.htm. We update 
guidances  periodically.  To make sure you  have the most recent version of a guidance, check the CDER  guidance  
page at  http://www.fda.gov/cder/guidance/index.htm  
 
  1
   
ICH Q10 demonstrates industry and regulatory authorities support of an effective 
pharmaceutical quality system to enhance the quality and availability of medicines around the 
world in the interest of public health. Implementation of ICH Q10 throughout the product 
lifecycle should facilitate  innovation and continual improvement and strengthen the link between 
pharmaceutical development and manufacturing activities.  
 
FDA's guidance documents, including this guidance, do not establish legally enforceable 
responsibilities. Instead, guidances describe the Agencys current thinking on a topic and should 
be viewed only as recommendations, unless specific regulatory or statutory requirements are 
cited. The use of the word should in Agency guidances means that something is suggested or 
recommended, but not required.  
 
 
II.  PHARMACEUTICAL QUALITY MANAGEMENT SYSTEM 
 
A.  Scope (1.2) 
 
This guidance applies to the systems supporting the development and manufacture of 
pharmaceutical drug substances (i.e., active pharmaceutical ingredients (APIs)) and drug 
products, including biotechnology and biological products, throughout the product lifecycle.  
 
The elements of ICH Q10 should be applied in a manner that is appropriate and proportionate to 
each of the product lifecycle stages, recognizing the differences among, and the different goals 
of, each stage (see section IV (3)).  
 
For the purposes of this guidance, the product lifecycle includes the following technical activities 
for new and existing products: 
   Pharmaceutical Development  
o   Drug substance development  
o   Formulation development (including container/closure system) 
o   Manufacture of investigational products 
o   Delivery system development (where relevant) 
o   Manufacturing process development and scale-up  
o   Analytical method development  
   Technology Transfer 
o   New product transfers during development through manufacturing  
o   Transfers within or between manufacturing and testing sites for marketed products  
   Commercial Manufacturing  
o   Acquisition and control of materials 
o   Provision of facilities, utilities, and equipment 
o   Production (including packaging and labeling)  
o   Quality control and assurance 
o   Release 
o   Storage 
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o   Distribution (excluding wholesaler activities) 
   Product Discontinuation 
o   Retention of documentation  
o   Sample retention  
o  Continued product assessment and reporting 
 
B. 	 Relationship of ICH Q10 to Regional GMP Requirements, ISO Standards, 
and ICH Q7 (1.3) 
 
Regional GMP requirements, the ICH guidance Q7 Good Manufacturing Practice Guidance for 
Active Pharmaceutical Ingredients, and ISO quality management system guidelines form the 
foundation for ICH Q10. To meet the objectives described below, ICH Q10 augments GMPs by 
describing specific quality system elements and management responsibilities. ICH Q10 provides 
a harmonized model for a pharmaceutical quality system throughout the lifecycle of a product 
and is intended to be used together with regional GMP requirements. 
 
The regional GMPs do not explicitly address all stages of the product lifecycle (e.g., 
development). The quality system elements and management responsibilities described in this 
guidance are intended to encourage the use of science- and risk-based approaches at each 
lifecycle stage, thereby promoting continual improvement across the entire product lifecycle.  
 
C. 	 Relationship of ICH Q10 to Regulatory Approaches (1.4) 
 
Regulatory approaches for a specific product or manufacturing facility should be commensurate 
with the level of product and process understanding, the results of quality risk management, and 
the effectiveness of the pharmaceutical quality system. When implemented, the effectiveness of 
the pharmaceutical quality system can normally be evaluated during a regulatory inspection at 
the manufacturing site. Potential opportunities to enhance science- and risk-based regulatory 
approaches are identified in Annex 1. Regulatory processes will be determined by region.  
 
D. 	 ICH Q10 Objectives (1.5) 
 
Implementation of the Q10 model should result in achievement of three main objectives that 
complement or enhance regional GMP requirements.  
 
1.  	Achieve Product Realization (1.5.1)  
 
To establish, implement, and maintain a system that allows the delivery of products with the 
quality attributes appropriate to meet the needs of patients, health care professionals, regulatory 
authorities (including compliance with approved regulatory filings) and other internal and 
external customers.  
 
2  Establish and Maintain a State of Control (1.5.2) 
 
  3
   
To develop and use effective monitoring and control systems for process performance and 
product quality, thereby providing assurance of continued suitability and capability of processes. 
Quality risk management can be useful in identifying the monitoring and control systems.  
 
3  Facilitate Continual Improvement (1.5.3)  
 
To identify and implement appropriate product quality improvements, process improvements, 
variability reduction, innovations, and pharmaceutical quality system enhancements, thereby 
increasing the ability to fulfill a pharmaceutical manufacturers own quality needs consistently. 
Quality risk management can be useful for identifying and prioritizing areas for continual 
improvement.  
 
E.  Enablers: Knowledge Management and Quality Risk Management (1.6) 
 
Use of knowledge management and quality risk management will enable a company to 
implement ICH Q10 effectively and successfully. These enablers will facilitate achievement of 
the objectives described in section II.D (1.5) above by providing the means for science- and risk-
based decisions related to product quality. 
 
1.  Knowledge Management (1.6.1)  
 
Product and process knowledge should be managed from development through the commercial 
life of the product up to and including product discontinuation. For example, development 
activities using scientific approaches provide knowledge for product and process understanding. 
Knowledge management is a systematic approach to acquiring, analyzing, storing, and 
disseminating information related to products, manufacturing processes, and components. 
Sources of knowledge include, but are not limited to, prior knowledge (public domain or 
internally documented); pharmaceutical development studies; technology transfer activities; 
process validation studies over the product lifecycle; manufacturing experience; innovation; 
continual improvement; and change management activities.  
 
2.  Quality Risk Management (1.6.2)  
 
Quality risk management is integral to an effective pharmaceutical quality system.  It can 
provide a proactive approach to identifying, scientifically evaluating, and controlling potential 
risks to quality. It facilitates continual improvement of process performance and product quality 
throughout the product lifecycle. ICH Q9 provides principles and examples of tools for quality 
risk management that can be applied to different aspects of pharmaceutical quality.  
   
F.  Design and Content Considerations (1.7) 
 
(a)  The design, organization, and documentation of the pharmaceutical quality system  
should be well structured and clear to facilitate common understanding and consistent  
application. 
(b)  The elements of ICH Q10 should be applied in a manner that is appropriate and 
proportionate to each of the product lifecycle stages, recognizing the different goals 
  4
   
and knowledge available for each stage. 
(c)  The size and complexity of the companys activities should be taken into consideration 
when developing a new pharmaceutical quality system or modifying an existing one. 
The design of the pharmaceutical quality system should incorporate appropriate risk 
management principles. While some aspects of the pharmaceutical quality system can 
be company wide and others site specific, the effectiveness of the pharmaceutical 
quality system is normally demonstrated at the site level.  
(d)  The pharmaceutical quality system should include appropriate processes, resources, 
and responsibilities to provide assurance of the quality of outsourced activities and 
purchased materials as described in section III.G (2.7).  
(e)  Management responsibilities, as described in section III (2), should be identified 
within the pharmaceutical quality system.  
(f)  The pharmaceutical quality system should include the following elements, as 
described in section IV (3): process performance and product quality monitoring, 
corrective and preventive action, change management, and management review.  
(g)  Performance indicators, as described in section V (4), should be identified and used to 
monitor the effectiveness of processes within the pharmaceutical quality system.  
G.  Quality Manual (1.8) 
 
A Quality Manual or equivalent documentation approach should be established and should 
contain the description of the pharmaceutical quality system. The description should include:  
(a)  The quality policy (see section III (2)). 
(b)  The scope of the pharmaceutical quality system. 
(c)  Identification of the pharmaceutical quality system processes, as well as their 
sequences, linkages, and interdependencies. Process maps and flow charts can be 
useful tools to facilitate depicting pharmaceutical quality system processes in a visual 
manner.  
(d)  Management responsibilities within the pharmaceutical quality system (see 
section III (2)). 
 
III.  MANAGEMENT RESPONSIBILITY (2) 
  
Leadership is essential to establish and maintain a company-wide commitment to quality and for 
the performance of the pharmaceutical quality system.  
 
A.  Management Commitment (2.1) 
 
(a)  Senior management has the ultimate responsibility to ensure an effective 
pharmaceutical quality system is in place to achieve the quality objectives, and that 
  5
   
roles, responsibilities, and authorities are defined, communicated, and implemented 
throughout the company.  
(b)  Management should:  
(1)  Participate in the design, implementation, monitoring, and maintenance of an 
effective pharmaceutical quality system. 
(2)  Demonstrate strong and visible support for the pharmaceutical quality system  
and ensure its implementation throughout their organization. 
(3)  Ensure a timely and effective communication and escalation process exists to 
raise quality issues to the appropriate levels of management. 
(4)  Define individual and collective roles, responsibilities, authorities, and inter-
relationships of all organizational units related to the pharmaceutical quality 
system. Ensure these interactions are communicated and understood at all 
levels of the organization. An independent quality unit/structure with authority 
to fulfill certain pharmaceutical quality system responsibilities is required by 
regional regulations. 
(5)  Conduct management reviews of process performance and product quality and 
of the pharmaceutical quality system. 
(6)  Advocate continual improvement. 
(7)  Commit appropriate resources. 
 
B.  Quality Policy (2.2) 
 
(a)  Senior management should establish a quality policy that describes the overall 
intentions and direction of the company related to quality.  
(b)  The quality policy should include an expectation to comply with applicable regulatory 
requirements and should facilitate continual improvement of the pharmaceutical 
quality system.  
(c)  The quality policy should be communicated to and understood by personnel at all 
levels in the company.  
(d)  The quality policy should be reviewed periodically for continuing effectiveness.  
 
C.  Quality Planning (2.3)  
 
(a)  Senior management should ensure the quality objectives to implement the quality 
policy are defined and communicated.  
(b)  Quality objectives should be supported by all relevant levels of the company.  
(c)  Quality objectives should align with the companys strategies and be consistent with 
the quality policy.  
(d)  Management should provide the appropriate resources and training to achieve the 
  6
   
quality objectives.  
(e)  Performance indicators that measure progress against quality objectives should be 
established, monitored, communicated regularly, and acted upon as appropriate as 
described in section V.A (4.1) of this document.  
 
D.  Resource Management (2.4) 
 
(a)  Management should determine and provide adequate and appropriate resources 
(human, financial, materials, facilities, and equipment) to implement and maintain the 
pharmaceutical quality system and continually improve its effectiveness.   
(b)  Management should ensure that resources are appropriately applied to a specific 
product, process, or site. 
 
E.  Internal Communication (2.5) 
 
(a)  Management should ensure appropriate communication processes are established and 
implemented within the organization.   
(b)  Communications processes should ensure the flow of appropriate information between 
all levels of the company.  
(c)  Communication processes should ensure the appropriate and timely escalation of 
certain product quality and pharmaceutical quality system issues.  
 
F.   Management Review (2.6) 
 
(a)  Senior management should be responsible for pharmaceutical quality system  
governance through management review to ensure its continuing suitability and 
effectiveness. 
(b)  Management should assess the conclusions of periodic reviews of process 
performance and product quality and of the pharmaceutical quality system, as 
described in sections IV (3) and V (4). 
 
G.  Management of Outsourced Activities and Purchased Materials  (2.7) 
 
The pharmaceutical quality system, including the management responsibilities described in this 
section, extends to the control and review of any outsourced activities and quality of purchased 
materials. The pharmaceutical company is ultimately responsible to ensure processes are in place 
to assure the control of outsourced activities and quality of purchased materials. These processes 
should incorporate quality risk management and include: 
 
(a)  Assessing prior to outsourcing operations or selecting material suppliers, the suitability 
and competence of the other party to carry out the activity or provide the material 
  7
   
using a defined supply chain (e.g., audits, material evaluations, qualification). 
(b)  Defining the responsibilities and communication processes for quality-related 
activities of the involved parties. For outsourced activities, this should be included in a 
written agreement between the contract giver and contract acceptor.  
(c)  Monitoring and review of the performance of the contract acceptor or the quality of  
the material from the provider, and the identification and implementation of any 
essential improvements. 
(d)  Monitoring incoming ingredients and materials to ensure they are from approved 
sources using the agreed supply chain.   
 
H. 	 Management of Change in Product Ownership (2.8) 
 
When product ownership changes (e.g., through acquisitions), management should consider the 
complexity of this and ensure:   
(a)  The ongoing responsibilities are defined for each company involved 
(b)  The essential information is transferred    
 
IV.  C	 ONTINUAL IMPROVEMENT OF PROCESS PERFORMANCE AND 
PRODUCT QUALITY (3) 
 
This section describes the lifecycle stage goals and the four specific pharmaceutical quality 
system elements that augment regional requirements to achieve the ICH Q10 objectives, as 
defined in section II.D (1.5). It does not restate all regional GMP requirements.  
 
A. 	 Lifecycle Stage Goals (3.1) 
 
The goals of each product lifecycle stage are described below.   
 
1. 	 Pharmaceutical Development (3.1.1) 
 
The goal of pharmaceutical development activities is to design a product and its manufacturing 
process to consistently deliver the intended performance and meet the needs of patients and 
healthcare professionals, and regulatory authorities and internal customers requirements. 
Approaches to pharmaceutical development are described in ICH Q8. The results of exploratory 
and clinical development studies, while outside the scope of this guidance, are inputs to 
pharmaceutical development.  
 
2.  T	 echnology Transfer (3.1.2)  
 
The goal of technology transfer activities is to transfer product and process knowledge between 
development and manufacturing, and within or between manufacturing sites to achieve product 
  8
   
realization. This knowledge forms the basis for the manufacturing process, control strategy, 
process validation approach, and ongoing continual improvement.  
 
3.  Commercial Manufacturing (3.1.3)  
 
The goals of manufacturing activities include achieving product realization, establishing and 
maintaining a state of control, and facilitating continual improvement. The pharmaceutical 
quality system should assure that the desired product quality is routinely met, suitable process 
performance is achieved, the set of controls are appropriate, improvement opportunities are 
identified and evaluated, and the body of knowledge is continually expanded.  
 
4.  Product Discontinuation (3.1.4)  
 
The goal of product discontinuation activities is to manage the terminal stage of the product 
lifecycle effectively. For product discontinuation, a predefined approach should be used to 
manage activities such as retention of documentation and samples and continued product 
assessment (e.g., complaint handling and stability) and reporting in accordance with regulatory 
requirements.  
 
B.  Pharmaceutical Quality System Elements (3.2) 
 
The elements described below might be required in part under regional GMP regulations. 
However, the Q10 models intent is to enhance these elements to promote the lifecycle approach 
to product quality. These four elements are:  
 
   Process performance and product quality monitoring system   
   Corrective action and preventive action (CAPA) system  
   Change management system  
   Management review of process performance and product quality 
 
These elements should be applied in a manner that is appropriate and proportionate to each of the 
product lifecycle stages, recognizing the differences among the stages and the different goals of 
each stage. Throughout the product lifecycle, companies are encouraged to evaluate 
opportunities for innovative approaches to improve product quality.  
 
Each element is followed by a table of example applications of the element to the stages of the 
pharmaceutical lifecycle.  
 
1.  Process Performance and Product Quality Monitoring System 3.2.1 
 
Pharmaceutical companies should plan and execute a system for the monitoring of process 
performance and product quality to ensure a state of control is maintained. An effective 
monitoring system provides assurance of the continued capability of processes and controls to 
produce a product of desired quality and to identify areas for continual improvement. The 
process performance and product quality monitoring system should:  
 
  9
   
(a)  Use quality risk management to establish the control strategy. This can include 
parameters and attributes related to drug substance and drug product materials and 
components, facility and equipment operating conditions, in-process controls, finished  
product specifications, and the associated methods and frequency of monitoring and 
control. The control strategy should facilitate timely feedback/feedforward and 
appropriate corrective action and preventive action.  
(b)  Provide the tools for measurement and analysis of parameters and attributes identified 
in the control strategy (e.g., data management and statistical tools).  
(c)  Analyze parameters and attributes identified in the control strategy to verify continued 
operation within a state of control. 
(d)  Identify sources of variation affecting process performance and product quality for 
potential continual improvement activities to reduce or control variation.  
(e)  Include feedback on product quality from both internal and external sources (e.g., 
complaints, product rejections, nonconformances, recalls, deviations, audits and 
regulatory inspections, and findings). 
(f)  Provide knowledge to enhance process understanding, enrich the design space (where  
established), and enable innovative approaches to process validation.  
Table I: Application of Process Performance and Product Quality Monitoring System 
Throughout the Product Lifecycle 
Pharmaceutical  Technology  Commercial  Product 
Development  Transfer  Manufacturing  Discontinuation 
Process and product  Monitoring during  A well-defined system   Once manufacturing 
knowledge generated  scale-up activities can  for process  ceases, monitoring 
and process and  provide a preliminary   performance and  such as stability testing 
product monitoring  indication of process  product quality  should continue to 
conducted throughout  performance and the  monitoring should be  completion of the 
development can be  successful integration  applied to assure  studies. Appropriate 
used to establish a  into manufacturing.  performance within a  action on marketed 
control strategy for  Knowledge obtained  state of control and to  product should  
manufacturing.  during transfer and  identify improvement  continue to be executed 
scale-up activities can  areas.  according to regional 
be useful in further  regulations. 
developing the control 
strategy.  
 
 
2.  Corrective Action and Preventive Action (CAPA) System (3.2.2)  
 
The pharmaceutical company should have a system for implementing corrective actions and 
preventive actions resulting from the investigation of complaints, product rejections, 
nonconformances, recalls, deviations, audits, regulatory inspections and findings, and trends 
from process performance and product quality monitoring. A structured approach to the 
  10
   
investigation process should be used with the objective of determining the root cause. The level 
of effort, formality, and documentation of the investigation should be commensurate with the 
level of risk, in line with ICH Q9. CAPA methodology should result in product and process 
improvements and enhanced product and process understanding.  
Table II: Application of Corrective Action and Preventive Action System Throughout the 
Product Lifecycle 
Pharmaceutical  Technology  Commercial  Product 
Development  Transfer  Manufacturing  Discontinuation 
Product or process  CAPA can be used as  CAPA should be used,  CAPA should continue 
variability is explored.  an effective system for  and the effectiveness of  after the product is 
CAPA methodology is  feedback, feedforward,  the actions should be  discontinued. The 
useful where corrective  and continual  evaluated.  impact on product 
actions and preventive  improvement.   remaining on the 
actions are incorporated  market should be 
into the iterative design  considered, as well as 
and development  other products that 
process.  might be affected. 
 
3.  Change Management System (3.2.3) 
 
Innovation, continual improvement, the outputs of process performance and product quality 
monitoring, and CAPA drive change. To evaluate, approve, and implement these changes 
properly, a company should have an effective change management system. There is generally a 
difference in formality of change management processes prior to the initial regulatory 
submission and after submission, where changes to the regulatory filing might be required under 
regional requirements.  
 
The change management system ensures continual improvement is undertaken in a timely and 
effective manner. It should provide a high degree of assurance there are no unintended 
consequences of the change. 
 
The change management system should include the following, as appropriate for the stage of the 
lifecycle: 
(a)  Quality risk management should be utilized to evaluate proposed changes. The level of  
effort and formality of the evaluation should be commensurate with the level of risk.  
(b)  Proposed changes should be evaluated relative to the marketing authorization, 
including design space, where established, and/or current product and process 
understanding. There should be an assessment to determine whether a change to the 
regulatory filing is required under regional requirements.  As stated in ICH Q8, 
working within the design space is not considered a change (from a regulatory filing 
perspective). However, from a pharmaceutical quality system standpoint, all changes 
should be evaluated by a companys change management system.  
(c)  Proposed changes should be evaluated by expert teams contributing the appropriate 
  11
   
expertise and knowledge from relevant areas (e.g., Pharmaceutical Development, 
Manufacturing, Quality, Regulatory Affairs, and Medical) to ensure the change is 
technically justified. Prospective evaluation criteria for a proposed change should be 
set. 
(d)  After implementation, an evaluation of the change should be undertaken to confirm the 
change objectives were achieved and that there was no deleterious impact on product 
quality. 
Table III: Application of Change Management System Throughout the Product Lifecycle 
Pharmaceutical  Technology  Commercial  Product 
Development  Transfer  Manufacturing  Discontinuation 
Change is an inherent  The change  A formal change  Any changes after 
part of the development  management system   management system   product discontinuation 
process and should be  should provide   should be in place for  should go through an 
documented; the  management and  commercial  appropriate change 
formality of the change  documentation of  manufacturing.  management system.  
management process  adjustments made to  Oversight by  the 
should be consistent  the process during  quality unit should  
with the stage of  technology transfer  provide assurance of 
pharmaceutical  activities.  appropriate science-
development.   and risk-based 
assessments.  
 
4.   Management Review of Process Performance and Product Quality (3.2.4) 
 
Management review should provide assurance that process performance and product quality are 
managed over the lifecycle. Depending on the size and complexity of the company, management 
review can be a series of reviews at various levels of management and should include a timely 
and effective communication and escalation process to raise appropriate quality issues to senior 
levels of management for review.  
 
(a)  The management review system should include:  
(1)  The results of regulatory inspections and findings, audits and other 
assessments, and commitments made to regulatory authorities 
(2)  Periodic quality reviews, that can include:  
(i) 	  Measures of customer satisfaction such as product quality complaints 
and recalls 
(ii)  	 Conclusions of process performance and product quality monitoring  
(iii) 	  The effectiveness of process and product changes including those 
arising from corrective action and preventive actions  
(3)  Any follow-up actions from previous management reviews  
(b)  The management review system should identify appropriate actions, such as:  
(1)  Improvements to manufacturing processes and products  
(2)  Provision, training, and/or realignment of resources  
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(3)  Capture and dissemination of knowledge  
Table IV: Application of Management Review of Process Performance and Product 
Quality Throughout the Product Lifecycle 
Pharmaceutical  Technology  Commercial  Product 
Development  Transfer  Manufacturing  Discontinuation 
Aspects of management  Aspects of  Management review  Management review 
review can be   management review  should be a structured  should include such 
performed to ensure  should be performed to  system, as described  items as product 
adequacy of the product  ensure the developed  above, and should  stability and product 
and process design.  product and process  support continual  quality complaints.  
can be manufactured at  improvement.  
commercial scale.  
 
 
V.  C	 ONTINUAL IMPROVEMENT OF THE PHARMACEUTICAL QUALITY 
SYSTEM (4) 
 
This section describes activities that should be conducted to manage and continually improve the 
pharmaceutical quality system.  
 
A. 	 Management Review of the Pharmaceutical Quality System (4.1) 
 
Management should have a formal process for reviewing the pharmaceutical quality system on a 
periodic basis. The review should include: 
(a)  Measurement of achievement of pharmaceutical quality system objectives  
(b)  Assessment of performance indicators that can be used to monitor the effectiveness of  
processes within the pharmaceutical quality system, such as:  
(1)  Complaint, deviation, CAPA and change management processes 
(2)  Feedback on outsourced activities 
(3)  Self-assessment processes including risk assessments, trending, and audits  
(4)  External assessments such as regulatory inspections and findings and customer 
audits 
 
B. 	 Monitoring of Internal and External Factors That Can Have an Impacton 
the Pharmaceutical Quality System (4.2) 
 
Factors monitored by management can include: 
(a)  Emerging regulations, guidance, and quality issues that can have an impact on the 
Pharmaceutical Quality System   
(b)  Innovations that might enhance the pharmaceutical quality system   
(c)  Changes in business environment and objectives  
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(d)  Changes in product ownership 
 
C.  Outcomes of Management Review and Monitoring (4.3) 
 
The outcome of management review of the pharmaceutical quality system and monitoring of 
internal and external factors can include:  
(a)  Improvements to the pharmaceutical quality system and related processes  
(b)  Allocation or reallocation of resources and/or personnel training 
(c)  Revisions to quality policy and quality objectives   
(d)  Documentation and timely and effective communication of the results of the 
management review and actions, including escalation of appropriate issues to senior 
management   
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VI.  GLOSSARY (5)  

 
ICH and ISO definitions are used in ICH Q10 where they exist. For the purpose of ICH Q10, 
where the words requirement, requirements, or necessary appear in an ISO definition, they 
do not necessarily reflect a regulatory requirement. The source of the definition is identified in 
parentheses after the definition. Where no appropriate ICH or ISO definition was available, an 
ICH Q10 definition was developed.  
 
Capability of a Process:   Ability of a process to realize a product that will fulfill the 
requirements of that product. The concept of process capability can also be defined in statistical 
terms. (ISO 9000:2005)  
 
Change Management: A systematic approach to proposing, evaluating, approving, 
implementing, and reviewing changes. (ICH Q10) 
 
Continual Improvement: Recurring activity to increase the ability to fulfill requirements. (ISO 
9000:2005)  
 
Control Strategy:  A planned set of controls, derived from current product and process 
understanding, that assures process performance and product quality. The controls can include 
parameters and attributes related to drug substance and drug product materials and components, 
facility and equipment operating conditions, in-process controls, finished product specifications, 
and the associated methods and frequency of monitoring and control. (ICH Q10) 
 
Corrective Action:  Action to eliminate the cause of a detected nonconformity or other 
undesirable situation. NOTE: Corrective action is taken to prevent recurrence whereas preventive 
action is taken to prevent occurrence. (ISO 9000:2005)  
 
Design Space:  The multidimensional combination and interaction of input variables (e.g., 
material attributes) and process parameters that have been demonstrated to provide assurance of 
quality. (ICH Q8)  
 
Enabler:  A tool or process that provides the means to achieve an objective. (ICH Q10) 
  
Feedback/Feedforward: 
 
Feedback: The modification or control of a process or system by its results or effects. 
 
Feedforward: The modification or control of a process using its anticipated results or  
effects. (Oxford Dictionary of English by Oxford University Press, 2003) 
 
Feedback/feedforward can be applied technically in process control strategies and conceptually 
in quality management. (ICH Q10)   
 
Innovation:  The introduction of new technologies or methodologies. (ICH Q10) 
 
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Knowledge Management:  Systematic approach to acquiring, analyzing, storing, and 
disseminating information related to products, manufacturing processes, and components. (ICH 
Q10) 
 
Outsourced Activities:  Activities conducted by a contract acceptor under a written agreement 
with a contract giver. (ICH Q10) 
 
Performance Indicators:  Measurable values used to quantify quality objectives to reflect the 
performance of an organization, process, or system, also known as performance metrics in some  
regions. (ICH Q10)  
 
Pharmaceutical Quality System (PQS):  Management system to direct and control a 
pharmaceutical company with regard to quality. (ICH Q10 based upon ISO 9000:2005) 
 
Preventive Action: Action to eliminate the cause of a potential nonconformity or other 
undesirable potential situation. NOTE: Preventive action is taken to prevent occurrence whereas 
corrective action is taken to prevent recurrence. (ISO 9000:2005) 
 
Product Realization:  Achievement of a product with the quality attributes appropriate to meet 
the needs of patients, health care professionals, and regulatory authorities (including compliance 
with marketing authorization) and internal customers requirements. (ICH Q10) 
 
Quality:   The degree to which a set of inherent properties of a product, system, or process fulfils 
requirements. (ICH Q9)  
 
Quality Manual:  Document specifying the quality management system of an organization. 
(ISO 9000:2005) 
  
Quality Objectives:  A means to translate the quality policy and strategies into measurable 
activities. (ICH Q10)  
 
Quality Planning:  Part of quality management focused on setting quality objectives and 
specifying necessary operational processes and related resources to fulfill the quality objectives. 
(ISO 9000:2005) 
 
Quality Policy:  Overall intentions and direction of an organization related to quality as formally 
expressed by senior management. (ISO 9000:2005)  
 
Quality Risk Management:  A systematic process for the assessment, control, communication, 
and review of risks to the quality of the drug (medicinal) product across the product lifecycle. 
(ICH Q9) 
  
Senior Management:  Person(s) who direct and control a company or site at the highest levels 
with the authority and responsibility to mobilize resources within the company or site. (ICH Q10 
based in part on ISO 9000:2005) 
 
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State of Control:  A condition in which the set of controls consistently provides assurance of 
continued process performance and product quality. (ICH Q10) 
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Annex I:  Potential Opportunities To Enhance Science- and Risk-Based 

Regulatory Approaches * 

 
*Note: This annex reflects potential opportunities to enhance regulatory approaches. The actual 
regulatory process will be determined by region. 
 
Scenario  Potential Opportunity 
1.  Comply with GMPs   Compliance  status quo  
2.  Demonstrate effective  Opportunity to: 
pharmaceutical quality system,     increase use of risk-based 
including effective use of quality  approaches for regulatory 
risk management principles (e.g.,  inspections 
ICH Q9 and ICH Q10).  
3.  Demonstrate product and process  Opportunity to: 
understanding, including effective     facilitate science-based 
use of quality risk management  pharmaceutical quality assessment  
principles (e.g., ICH Q8 and ICH     enable innovative approaches to 
Q9).  process validation 
   establish real-time release 
mechanisms   
4.  Demonstrate effective  Opportunity to: 
pharmaceutical quality system and     increase use of risk-based 
product and process understanding,  approaches for regulatory 
including the use of quality risk  inspections; 
management principles (e.g., ICH     facilitate science-based 
Q8, ICH Q9, and ICH Q10).  pharmaceutical quality assessment;  
   optimize science- and risk-based 
postapproval change processes to 
maximize benefits from innovation 
and continual improvement;  
   enable innovative approaches to 
process validation; 
   establish real-time release 
mechanisms.  
 
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Annex 2
 
Diagram of  the ICH Q10  Pharmaceutical Quality System Model 

ICH Q10   Pharmaceutical  Quality System 
Pharmaceutical   Technology   Commercial  Product 
Development  Transfer  Manufacturing  Discontinuation 
Investigational products 
GMP 
Management Responsibilities 
Process Performance & Product Quality Monitoring System 
Corrective Action / Preventive Action  (CAPA) System 
PQS 
Change Management  System 
elements 
Management Review 
Knowledge Management 
Enablers 
Quality Risk Management 
   
 
 
This diagram illustrates the major features of the ICH Q10 Pharmaceutical Quality System  
(PQS) model. The PQS covers the entire lifecycle of a product including pharmaceutical 
development, technology transfer, commercial manufacturing, and product discontinuation as 
illustrated by the upper portion of the diagram. The PQS augments regional GMPs as illustrated 
in the diagram. The diagram also illustrates that regional GMPs apply to the manufacture of  
investigational products. 
 
The next horizontal bar illustrates the importance of management responsibilities explained in 
section III (2) to all stages of the product lifecycle.  The following horizontal bar lists the PQS 
elements that serve as the major pillars under the PQS model. These elements should be applied 
appropriately and proportionally to each lifecycle stage, recognizing opportunities to identify 
areas for continual improvement. 
 
The bottom set of horizontal bars illustrates the enablers: knowledge management and quality 
risk management, which are applicable throughout the lifecycle stages.  These enablers support 
the PQS goals of achieving product realization, establishing and maintaining a state of control, 
and facilitating continual improvement. 
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