Q7 Good Manufacturing 
Practice Guidance for Active  
Pharmaceutical Ingredients 
 
 
Guidance for Industry 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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) 
September 2016 
ICH 
 
Revision 1 
 
       
     
 
Q7 Good Manufacturing 
Practice Guidance for Active  
Pharmaceutical Ingredients 
 
 
Guidance for Industry 
 
 
Additional copies are available from: 
 
Office of Communications, Division of Drug Information  
Center for Drug Evaluation and Research 
Food and Drug Administration 
10001 New Hampshire Ave., Hillandale Bldg., 4th Floor  
Silver Spring, MD 20993-0002  
Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353 
Email: druginfo@fda.hhs.gov  
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm 
or 
Office of Communication, Outreach and Development  
Center for Biologics Evaluation and Research 
 Food and Drug Administration 
10903 New Hampshire Ave., Bldg. 71, Room 3128 
Silver Spring, MD 20993-0002 
Phone: 800-835-4709 or 240-402-8010 
Email: ocod@fda.hhs.gov 
http://www.fda.gov/BiologicsBloodVaccines/GuidanceComplianceRegulatoryInformation/Guidances/default.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) 
September 2016 
ICH 
 
Revision 1 
      Contains Nonbinding Recommendations 
 
     
Table Of Contents 
 
 
I.  INTRODUCTION (1) ........................................................................................................... 1 
A.  Objective (1.1) ................................................................................................................................ 1 
B.  Regulatory Applicability (1.2) ...................................................................................................... 2 
C.  Scope (1.3) ....................................................................................................................................... 2 
II.  QUALITY MANAGEMENT (2) ......................................................................................... 5 
A.  Principles (2.1) ............................................................................................................................... 5 
B.   Responsibilities of the Quality Unit(s) (2.2) ............................................................................... 5 
C.  Responsibility for Production Activities (2.3) ............................................................................. 6 
D.  Internal Audits (Self Inspection) (2.4) ......................................................................................... 7 
E.  Product Quality Review (2.5) ....................................................................................................... 7 
III.  PERSONNEL (3)................................................................................................................... 8 
A.  Personnel Qualifications (3.1) ....................................................................................................... 8 
B.  Personnel Hygiene (3.2) ................................................................................................................. 8 
C.  Consultants (3.3) ............................................................................................................................ 9 
IV.  BUILDINGS AND FACILITIES (4) ................................................................................... 9 
A.  Design and Construction (4.1) ...................................................................................................... 9 
B.  Utilities (4.2) ................................................................................................................................. 10 
C.  Water (4.3) .................................................................................................................................... 10 
D.  Containment  (4.4) ....................................................................................................................... 11 
E.  Lighting (4.5) ................................................................................................................................ 11 
F.  Sewage and Refuse (4.6) .............................................................................................................. 11 
G.  Sanitation and Maintenance (4.7) .............................................................................................. 11 
V.  PROCESS EQUIPMENT (5) ............................................................................................. 12 
A.  Design and Construction (5.1) .................................................................................................... 12 
B.  Equipment Maintenance and Cleaning (5.2)............................................................................. 13 
C.  Calibration (5.3) ........................................................................................................................... 13 
D.  Computerized Systems (5.4) ....................................................................................................... 14 
VI.  DOCUMENTATION AND RECORDS (6) ...................................................................... 15 
A.  Documentation System and Specifications (6.1) ....................................................................... 15 
B.  Equipment Cleaning and Use Record (6.2) ............................................................................... 16 
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C.  Records of Raw Materials, Intermediates, API Labeling and Packaging Materials (6.3) ... 16 
D.  Master Production Instructions (Master Production and Control Records) (6.4) ................ 16 
E.  Batch Production Records (Batch Production and Control Records) (6.5) ........................... 17 
F.  Laboratory Control Records (6.6) .............................................................................................. 18 
G.  Batch Production Record Review (6.7)...................................................................................... 19 
VII.  MATERIALS MANAGEMENT (7) ............................................................................. 19 
A.  General Controls (7.1) ................................................................................................................. 19 
B.  Receipt and Quarantine (7.2)...................................................................................................... 20 
C.  Sampling and Testing of Incoming Production Materials (7.3) .............................................. 20 
D.  Storage (7.4) .................................................................................................................................. 21 
E.  Re-evaluation (7.5) ....................................................................................................................... 21 
VIII.  PRODUCTION AND IN-PROCESS CONTROLS (8) ............................................... 21 
A.  Production Operations (8.1) ....................................................................................................... 22 
B.  Time Limits (8.2) .......................................................................................................................... 22 
C.  In-process Sampling and Controls (8.3) .................................................................................... 23 
D.  Blending Batches of Intermediates or APIs (8.4) ..................................................................... 23 
E.  Contamination Control (8.5)....................................................................................................... 24 
IX.  PACKAGING AND IDENTIFICATION LABELING OF APIs AND 
INTERMEDIATES (9) ............................................................................................................... 24 
A.  General      (9.1) ............................................................................................................................ 25 
B.  Packaging Materials (9.2) ........................................................................................................... 25 
C.  Label Issuance and Control (9.3) ............................................................................................... 25 
D.  Packaging and Labeling Operations (9.4) ................................................................................. 26 
X.  STORAGE AND DISTRIBUTION (10) ........................................................................... 26 
A.  Warehousing Procedures (10.1) ................................................................................................. 26 
B.  Distribution Procedures (10.2) ................................................................................................... 27 
XI.  LABORATORY CONTROLS (11) ................................................................................... 27 
A.  General Controls (11.1) ............................................................................................................... 27 
B.  Testing of Intermediates and APIs (11.2) .................................................................................. 28 
C.  Validation of Analytical Procedures - See Section 12. (11.3) ................................................... 29 
D.  Certificates of Analysis (11.4) ..................................................................................................... 29 
E.  Stability Monitoring of APIs (11.5) ............................................................................................ 30 
F.  Expiry and Retest Dating (11.6) ................................................................................................. 30 
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G.  Reserve/Retention Samples (11.7) .............................................................................................. 31 
XII.  VALIDATION (12) ......................................................................................................... 31 
A.  Validation Policy (12.1) ............................................................................................................... 31 
B.  Validation Documentation (12.2) ............................................................................................... 32 
C.  Qualification (12.3) ...................................................................................................................... 32 
D.  Approaches to Process Validation (12.4) ................................................................................... 32 
E.  Process Validation Program (12.5) ............................................................................................ 33 
F.  Periodic Review of Validated Systems (12.6) ............................................................................ 34 
G.  Cleaning Validation (12.7) .......................................................................................................... 34 
H.  Validation of Analytical Methods (12.8) .................................................................................... 35 
XIII.  CHANGE CONTROL (13) ............................................................................................ 35 
XIV.  REJECTION AND RE-USE OF MATERIALS (14) .................................................. 36 
A.  Rejection (14.1) ............................................................................................................................ 36 
B.  Reprocessing (14.2) ...................................................................................................................... 36 
C.  Reworking (14.3) .......................................................................................................................... 37 
D.  Recovery of Materials and Solvents (14.4) ................................................................................ 37 
E.  Returns (14.5) ............................................................................................................................... 37 
XV.  COMPLAINTS AND RECALLS (15) .......................................................................... 38 
XVI.  CONTRACT MANUFACTURERS (INCLUDING LABORATORIES) (16) .......... 39 
XVII.  AGENTS, BROKERS, TRADERS, DISTRIBUTORS, REPACKERS, AND 
RELABELLERS (17) ................................................................................................................. 39 
A.  Applicability (17.1) ...................................................................................................................... 39 
B.  Traceability of Distributed APIs and Intermediates (17.2) ..................................................... 39 
C.  Quality Management (17.3) ........................................................................................................ 40 
D.  Repackaging, Relabeling, and Holding of APIs and Intermediates (17.4) ............................. 40 
E.  Stability (17.5) .............................................................................................................................. 40 
F.  Transfer of Information (17.6) ................................................................................................... 40 
G.  Handling of Complaints and Recalls (17.7) ............................................................................... 41 
H.  Handling of Returns (17.8) ......................................................................................................... 41 
XVIII. SPECIFIC GUIDANCE FOR APIs MANUFACTURED BY CELL 
CULTURE/FERMENTATION (18) ......................................................................................... 41 
A.  General (18.1) ............................................................................................................................... 41 
B.  Cell Bank Maintenance and Record Keeping (18.2) ................................................................ 43 
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C.  Cell Culture/Fermentation (18.3) ............................................................................................... 43 
D.  Harvesting, Isolation and Purification (18.4) ............................................................................ 44 
E.  Viral Removal/Inactivation steps (18.5) .................................................................................... 44 
XIX.  APIs FOR USE IN CLINICAL TRIALS (19) .............................................................. 45 
A.  General (19.1) ............................................................................................................................... 45 
B.  Quality (19.2) ................................................................................................................................ 45 
C.  Equipment and Facilities (19.3) .................................................................................................. 46 
D.  Control of Raw Materials (19.4) ................................................................................................. 46 
E.  Production (19.5).......................................................................................................................... 46 
F.  Validation (19.6) ........................................................................................................................... 46 
G.  Changes (19.7) .............................................................................................................................. 46 
H.  Laboratory Controls (19.8) ......................................................................................................... 47 
I.  Documentation (19.9) .................................................................................................................. 47 
GLOSSARY (20) ......................................................................................................................... 48 
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Q7 Good Manufacturing Practice Guidance for Active  
Pharmaceutical Ingredients 
1
Guidance for Industry  
 
 
 
This guidance represents the current thinking of  the Food and Drug Administration (FDA or 
Agency) on this topic.  It does not establish any rights for any person and is not binding on 
 
FDA or the public. You can use an alternative approach if it satisfies the requirements of the 
applicable statutes and regulations.  To discuss  an alternative approach, contact the FDA 
office responsible for this guidance as listed on the title page. 
 
 
 
 
 
I.  INTRODUCTION (1) 
 
A.  Objective (1.1) 
 
This document is intended to provide guidance regarding good manufacturing practice (GMP) for 
the manufacturing of active pharmaceutical ingredients (APIs) under an appropriate system for 
managing quality.  It is also intended to help ensure that APIs meet the quality and purity 
characteristics that they purport, or are represented, to possess.  
 
In this guidance, the term manufacturing is defined to include all operations of receipt of 
materials, production, packaging, repackaging, labeling, relabeling, quality control, release, 
storage and distribution of APIs and the related controls.   In this guidance, the term should 
identifies recommendations that, when followed, will ensure compliance with CGMPs.  An 
alternative approach may be used if such approach satisfies the requirements of the applicable 
statutes.  For the purposes of this guidance, the terms current good manufacturing practices and 
good manufacturing practices are equivalent. 
 
The guidance as a whole does not cover safety aspects for the personnel engaged in 
manufacturing, nor aspects related to protecting the environment.  These controls are inherent 
responsibilities of the manufacturer and are governed by national laws.   
                                                 
1 This guidance was developed within the Expert Working Group (Q7A) 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, November  2000.  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. 
Arabic numbers in subheadings reflect the organizational breakdown in the document endorsed by the ICH  Steering 
Committee at Step 4 of the ICH process, November 2000.  
 
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This guidance is not intended to define registration and/or filing requirements or modify 
pharmacopoeial requirements.  This guidance does not affect the ability of the responsible 
regulatory agency to establish specific registration/filing requirements regarding APIs within the 
context of marketing/manufacturing authorizations or drug applications.  All commitments in 
registration/filing documents should be met.  
 
This guidance revises and replaces the guidance Q7A Good Manufacturing Practice Guidance for 
Active Pharmaceutical Ingredients.  This revision changes the ICH codification from Q7A to Q7. 
This revision also adds the ICH section numbers in parentheses at the end of each paragraph in 
Sections II (2) through XIX (19) of the guidance. 
 
B.  Regulatory Applicability (1.2)  
 
Within the world community, materials may vary as to their legal classification as an API. When 
a material is classified as an API in the region or country in which it is manufactured or used in a 
drug product, it should be manufactured according to this guidance. 
 
C.  Scope (1.3) 
 
This guidance applies to the manufacture of APIs for use in human drug (medicinal) products. It 
applies to the manufacture of sterile APIs only up to the point immediately prior to the APIs 
being rendered sterile. The sterilization and aseptic processing of sterile APIs are not covered by 
this guidance, but should be performed in accordance with GMP guidances for drug (medicinal) 
products as defined by local authorities.  
 
This guidance covers APIs that are manufactured by chemical synthesis, extraction, cell 
culture/fermentation, recovery from natural sources, or any combination of these processes.   
Specific guidance for APIs manufactured by cell culture/fermentation is described in Section 
XVIII (18). 
 
This guidance excludes all vaccines, whole cells, whole blood and plasma, blood and plasma 
derivatives (plasma fractionation), and gene therapy APIs.  However, it does include APIs that 
are produced using blood or plasma as raw materials. Note that cell substrates (mammalian, 
plant, insect or microbial cells, tissue or animal sources including transgenic animals) and early 
process steps may be subject to GMP but are not covered by this guidance.  In addition, the 
guidance does not apply to medical gases, bulk-packaged drug (medicinal) products (e.g., tablets 
or capsules in bulk containers), or radiopharmaceuticals.  
 
Section XIX (19) contains guidance that only applies to the manufacture of APIs used in the 
production of drug (medicinal) products specifically for clinical trials (investigational medicinal 
products). 
 
An API starting material is a raw material, an intermediate, or an API that is used in the 
production of an API and that is incorporated as a significant structural fragment into the 
structure of the API.  An API starting material can be an article of commerce, a material 
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purchased from one or more suppliers under contract or commercial agreement, or produced in-
house.  API starting materials normally have defined chemical properties and structure.   
 
The company should designate and document the rationale for the point at which production of 
the API begins.  For synthetic processes, this is known as the point at which API starting 
materials are entered into the process.  For other processes (e.g., fermentation, extraction, 
purification), this rationale should be established on a case-by-case basis. Table 1 gives guidance 
on the point at which the API starting material is normally introduced into the process. 
 
From this point on, appropriate GMP as defined in this guidance should be applied to 
these intermediate and/or API manufacturing steps. This would include the validation of 
critical process steps determined to impact the quality of the API.  However, it should be 
noted that the fact that a company chooses to validate a process step does not necessarily 
define that step as critical. 
 
The guidance in this document would normally be applied to the steps shown in gray in Table 1.  
However, all steps shown may not need to be completed.   The stringency of GMP in API 
manufacturing should increase as the process proceeds from early API steps to final steps, 
purification, and packaging.  Physical processing of APIs, such as granulation, coating or 
physical manipulation of particle size (e.g., milling, micronizing) should be conducted according 
to this guidance. 
 
This GMP guidance does not apply to steps prior to the introduction of the defined API starting 
material. 
 
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Table 1:  Application of this Guidance to API Manufacturing 
 
Type of  Application of this guidance to steps (shown in gray) used in this type of 
Manufacturing  manufacturing  
Chemical  Production of  Introduction  Production of  Isolation  Physical 
Manufacturing  the API  of the API  Intermediate(s)  and  processing, and 
starting  starting    purification  packaging 
material  material into   
process 
API derived  Collection of  Cutting,  Introduction of  Isolation  Physical 
from animal  organ, fluid,  mixing,  the API starting  and  processing, and 
sources  or tissue  and/or initial  material into  purification  packaging 
processing  process 
API extracted  Collection of  Cutting and  Introduction of  Isolation  Physical 
from plant  plant  initial  the API starting  and  processing, and 
sources   extraction(s)  material into  purification  packaging 
  process 
Herbal extracts  Collection of  Cutting and    Further  Physical 
used as API   plants  initial  extraction  processing, and 
extraction  packaging 
API consisting of   Collection of  Cutting/      Physical 
comminuted or  plants and/or  comminuting  processing, and 
powdered herbs  cultivation  packaging 
and 
harvesting 
Biotechnology:  Establish- Maintenance  Cell culture  Isolation  Physical 
fermentation/  ment of  of working  and/or  and  processing, and 
cell culture  master cell  cell bank  fermentation   purification  packaging 
bank and 
working cell 
bank 
Classical  Establish- Maintenance  Introduction of  Isolation  Physical 
Fermentation to  ment of cell  of the cell  the cells into  and  processing, and 
produce an API  bank  bank  fermentation   purification  packaging 
 
 
 
Increasing GMP requirements 
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II.  QUALITY MANAGEMENT (2) 
 
A.  Principles (2.1)  
  
Quality should be the responsibility of all persons involved in manufacturing. (2.10) 
 
Each manufacturer should establish, document, and implement an effective system for managing 
quality that involves the active participation of management and appropriate manufacturing 
personnel. (2.11) 
 
The system for managing quality should encompass the organizational structure, procedures, 
processes and resources, as well as activities to ensure confidence that the API will meet its 
intended specifications for quality and purity. All quality-related activities should be defined and 
documented. (2.12) 
 
There should be a quality unit(s) that is independent of production and that fulfills both quality 
assurance (QA) and quality control (QC) responsibilities.  The quality unit can be in the form of 
separate QA and QC units or a single individual or group, depending upon the size and structure 
of the organization. (2.13) 
 
The persons authorized to release intermediates and APIs should be specified. (2.14) 
 
All quality-related activities should be recorded at the time they are performed. (2.15) 
 
Any deviation from established procedures should be documented and explained. Critical 
deviations should be investigated, and the investigation and its conclusions should be 
documented. (2.16) 
 
No materials should be released or used before the satisfactory completion of evaluation by the 
quality unit(s) unless there are appropriate systems in place to allow for such use (e.g., release 
under quarantine as described in Section X (10) or the use of raw materials or intermediates 
pending completion of evaluation). (2.17) 
 
Procedures should exist for notifying responsible management in a timely manner of regulatory 
inspections, serious GMP deficiencies, product defects and related actions  (e.g., quality-related 
complaints, recalls, and regulatory actions). (2.18) 
 
B.   Responsibilities of the Quality Unit(s) (2.2) 
 
The quality unit(s) should be involved in all quality-related matters.  (2.20) 
 
The quality unit(s) should review and approve all appropriate quality-related documents. (2.21) 
 
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The main responsibilities of the independent quality unit(s) should not be delegated.  These 
responsibilities should be described in writing and should include, but not necessarily be limited 
to the following: (2.22) 
 
1.  Releasing or rejecting all APIs.  Releasing or rejecting intermediates for use 
outside the control of the manufacturing company 
 
2.    Establishing a system to release or reject raw materials, intermediates, packaging, 
and labeling materials 
 
3.   Reviewing completed batch production and laboratory control records of critical 
process steps before release of the API for distribution  
 
4.   Making sure that critical deviations are investigated and resolved 
 
5.   Approving all specifications and master production instructions 
 
6.    Approving all procedures affecting the quality of intermediates or APIs 
 
7.   Making sure that internal audits (self-inspections) are performed 
 
8.   Approving intermediate and API contract manufacturers 
 
9.   Approving changes that potentially affect intermediate or API quality 
 
10.   Reviewing and approving validation protocols and reports  
 
11.   Making sure that quality-related complaints are investigated and resolved 
 
12.   Making sure that effective systems are used for maintaining and calibrating 
critical equipment 
 
13.  Making sure that materials are appropriately tested and the results are reported  
 
14.  Making sure that there is stability data to support retest or expiry dates and storage 
conditions on APIs and/or intermediates, where appropriate 
 
15.  Performing product quality reviews (as defined in Section 2.5) 
 
C.  Responsibility for Production Activities (2.3) 
   
The responsibility for production activities should be described in writing and should include, but 
not necessarily be limited to:  
 
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 1.  Preparing, reviewing, approving, and distributing the instructions for the 
production of intermediates or APIs according to written procedures 
 
 2.  Producing APIs and, when appropriate, intermediates according to pre-approved 
instructions 
 
 3.   Reviewing all production batch records and ensuring that these are completed and 
signed 
 
 4.   Making sure that all production deviations are reported and evaluated and that 
critical deviations are investigated and the conclusions are recorded 
 
 5.   Making sure that production facilities are clean and, when appropriate, disinfected 
 
 6.   Making sure that the necessary calibrations are performed and records kept 
 
 7.   Making sure that the premises and equipment are maintained and records kept 
 
 8.   Making sure that validation protocols and reports are reviewed and approved 
  
 9.   Evaluating proposed changes in product, process or equipment 
 
10.  Making sure that new and, when appropriate, modified facilities and equipment are 
qualified 
 
D.  Internal Audits (Self Inspection) (2.4) 
 
To verify compliance with the principles of GMP for APIs, regular internal audits should be 
performed in accordance with an approved schedule. (2.40) 
 
Audit findings and corrective actions should be documented and brought to the attention of 
responsible management of the firm.  Agreed corrective actions should be completed in a timely 
and effective manner. (2.41) 
 
E.  Product Quality Review (2.5)  
 
Regular quality-reviews of APIs should be conducted with the objective of verifying the 
consistency of the process.  Such reviews should normally be conducted and documented 
annually and should include at least the following: (2.50) 
 
  A review of critical in-process control and critical API test results 
  A review of all batches that failed to meet established specification(s) 
  A review of all critical deviations or nonconformances and related investigations 
  A review of any changes carried out to the processes or analytical methods; 
  A review of results of the stability monitoring program 
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  A review of all quality-related returns, complaints and recalls 
  A review of adequacy of corrective actions 
 
The results of this review should be evaluated and an assessment made of whether corrective 
action or any revalidation should be undertaken.  Reasons for such corrective action should be 
documented.  Agreed corrective actions should be completed in a timely and effective manner. 
(2.51) 
 
 
III.  PERSONNEL (3) 
 
A.  Personnel Qualifications (3.1) 
 
There should be an adequate number of personnel qualified by appropriate education, training, 
and/or experience to perform and supervise the manufacture of intermediates and APIs. (3.10) 
 
The responsibilities of all personnel engaged in the manufacture of intermediates and APIs 
should be specified in writing. (3.11) 
 
Training should be regularly conducted by qualified individuals and should cover, at a minimum, 
the particular operations that the employee performs and GMP as it relates to the employee's 
functions.  Records of training should be maintained. Training should be periodically assessed. 
(3.12) 
 
B.  Personnel Hygiene (3.2) 
 
Personnel should practice good sanitation and health habits. (3.20) 
 
Personnel should wear clean clothing suitable for the manufacturing activity with which they are 
involved and this clothing should be changed, when appropriate. Additional protective apparel, 
such as head, face, hand, and arm coverings, should be worn, when necessary, to protect 
intermediates and APIs from contamination. (3.21) 
 
Personnel should avoid direct contact with intermediates or APIs. (3.22) 
 
Smoking, eating, drinking, chewing and the storage of food should be restricted to certain 
designated areas separate from the manufacturing areas. (3.23) 
 
Personnel suffering from an infectious disease or having open lesions on the exposed surface of 
the body should not engage in activities that could result in compromising the quality of APIs.  
Any person shown at any time (either by medical examination or supervisory observation) to 
have an apparent illness or open lesions should be excluded from activities where the health 
condition could adversely affect the quality of the APIs until the condition is corrected or 
qualified medical personnel determine that the person's inclusion would not jeopardize the safety 
or quality of the APIs. (3.24) 
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C.  Consultants (3.3) 
 
Consultants advising on the manufacture and control of intermediates or APIs should have 
sufficient education, training, and experience, or any combination thereof, to advise on the 
subject for which they are retained. (3.30) 
 
Records should be maintained stating the name, address, qualifications, and type of service 
provided by these consultants. (3.31) 
 
 
IV.  BUILDINGS AND FACILITIES (4) 
 
A.  Design and Construction (4.1)  
 
Buildings and facilities used in the manufacture of intermediates and APIs should be located, 
designed, and constructed to facilitate cleaning, maintenance, and operations as appropriate to the 
type and stage of manufacture.  Facilities should also be designed to minimize potential 
contamination.   Where microbiological specifications have been established for the intermediate 
or API, facilities should also be designed to limit exposure to objectionable microbiological 
contaminants, as appropriate. (4.10) 
 
Buildings and facilities should have adequate space for the orderly placement of equipment and 
materials to prevent mix-ups and contamination. (4.11) 
 
Where the equipment itself (e.g., closed or contained systems) provides adequate protection of 
the material, such equipment can be located outdoors. (4.12) 
 
The flow of materials and personnel through the building or facilities should be designed to 
prevent mix-ups or contamination. (4.13) 
 
There should be defined areas or other control systems for the following activities: (4.14) 
 
  Receipt, identification, sampling, and quarantine of incoming materials, pending 
release or rejection 
  Quarantine before release or rejection of intermediates and APIs 
  Sampling of intermediates and APIs 
  Holding rejected materials before further disposition (e.g., return, reprocessing or 
destruction) 
  Storage of released materials 
  Production operations 
  Packaging and labeling operations 
  Laboratory operations 
 
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Adequate and clean washing and toilet facilities should be provided for personnel.  These 
facilities should be equipped with hot and cold water, as appropriate, soap or detergent, air 
dryers, or single service towels.  The washing and toilet facilities should be separate from, but 
easily accessible to, manufacturing areas.  Adequate facilities for showering and/or changing 
clothes should be provided, when appropriate. (4.15) 
 
Laboratory areas/operations should normally be separated from production areas.  Some 
laboratory areas, in particular those used for in-process controls, can be located in production 
areas, provided the operations of the production process do not adversely affect the accuracy of 
the laboratory measurements, and the laboratory and its operations do not adversely affect the 
production process, intermediate, or API. (4.16) 
 
B.  Utilities (4.2)  
 
All utilities that could affect product quality (e.g., steam, gas, compressed air, heating, 
ventilation, and air conditioning) should be qualified and appropriately monitored and action 
should be taken when limits are exceeded.  Drawings for these utility systems should be 
available.  (4.20) 
 
Adequate ventilation, air filtration and exhaust systems should be provided, where appropriate.  
These systems should be designed and constructed to minimize risks of contamination and cross-
contamination and should include equipment for control of air pressure, microorganisms (if 
appropriate), dust, humidity, and temperature, as appropriate to the stage of manufacture.  
Particular attention should be given to areas where APIs are exposed to the environment. (4.21) 
 
If air is recirculated to production areas, appropriate measures should be taken to control risks of 
contamination and cross-contamination. (4.22) 
 
Permanently installed pipework should be appropriately identified. This can be accomplished by 
identifying individual lines, documentation, computer control systems, or alternative means.  
Pipework should be located to avoid risks of contamination of the intermediate or API. (4.23) 
 
Drains should be of adequate size and should be provided with an air break or a suitable device 
to prevent back-siphonage, when appropriate. (4.24) 
 
C.  Water (4.3)  
 
Water used in the manufacture of APIs should be demonstrated to be suitable for its intended 
use. (4.30) 
 
Unless otherwise justified, process water should, at a minimum, meet World Health Organization 
(WHO) guidelines for drinking (potable) water quality. (4.31) 
 
If drinking (potable) water is insufficient to ensure API quality and tighter chemical and/or 
microbiological water quality specifications are called for, appropriate specifications for 
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physical/chemical attributes, total microbial counts, objectionable organisms, and/or endotoxins 
should be established. (4.32) 
 
Where water used in the process is treated by the manufacturer to achieve a defined quality, the 
treatment process should be validated and monitored with appropriate action limits. (4.33) 
 
Where the manufacturer of a nonsterile API either intends or claims that it is suitable for use in 
further processing to produce a sterile drug (medicinal) product, water used in the final isolation 
and purification steps should be monitored and controlled for total microbial counts, 
objectionable organisms, and endotoxins. (4.34) 
 
D.  Containment  (4.4) 
 
Dedicated production areas, which can include facilities, air handling equipment and/or process 
equipment, should be employed in the production of highly sensitizing materials, such as 
penicillins or cephalosporins. (4.40) 
 
The use of dedicated production areas should also be considered when material of an infectious 
nature or high pharmacological activity or toxicity is involved (e.g., certain steroids or cytotoxic 
anti-cancer agents) unless validated inactivation and/or cleaning procedures are established and 
maintained. (4.41) 
 
Appropriate measures should be established and implemented to prevent cross-contamination 
from personnel and materials moving from one dedicated area to another. (4.42) 
 
Any production activities (including weighing, milling, or packaging) of highly toxic 
nonpharmaceutical materials, such as herbicides and pesticides, should not be conducted using 
the buildings and/or equipment being used for the production of APIs.  Handling and storage of 
these highly toxic nonpharmaceutical materials should be separate from APIs. (4.43) 
 
E.  Lighting (4.5) 
 
Adequate lighting should be provided in all areas to facilitate cleaning, maintenance, and proper 
operations. (4.50) 
 
F.  Sewage and Refuse (4.6) 
 
Sewage, refuse, and other waste (e.g., solids, liquids, or gaseous by-products from 
manufacturing) in and from buildings and the immediate surrounding area should be disposed of 
in a safe, timely, and sanitary manner. Containers and/or pipes for waste material should be 
clearly identified.  (4.60) 
 
G.  Sanitation and Maintenance (4.7) 
 
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Buildings used in the manufacture of intermediates and APIs should be properly maintained and 
repaired and kept in a clean condition. (4.70) 
 
Written procedures should be established assigning responsibility for sanitation and describing 
the cleaning schedules, methods, equipment, and materials to be used in cleaning buildings and 
facilities. (4.71) 
 
When necessary, written procedures should also be established for the use of suitable 
rodenticides, insecticides, fungicides, fumigating agents, and cleaning and sanitizing agents to 
prevent the contamination of equipment, raw materials, packaging/labeling materials, 
intermediates, and APIs. (4.72) 
  
 
V.  PROCESS EQUIPMENT (5) 
 
A.  Design and Construction (5.1)  
 
Equipment used in the manufacture of intermediates and APIs should be of appropriate design 
and adequate size, and suitably located for its intended use, cleaning, sanitation (where 
appropriate), and maintenance. (5.10) 
 
Equipment should be constructed so that surfaces that contact raw materials, intermediates, or 
APIs do not alter the quality of the intermediates and APIs beyond the official or other 
established specifications. (5.11) 
 
Production equipment should only be used within its qualified operating range. (5.12) 
 
Major equipment (e.g., reactors, storage containers) and permanently installed processing lines 
used during the production of an intermediate or API should be appropriately identified.  (5.13) 
 
Any substances associated with the operation of equipment, such as lubricants, heating fluids or 
coolants, should not contact intermediates or APIs so as to alter the quality of APIs or 
intermediates beyond the official or other established specifications.  Any deviations from this 
practice should be evaluated to ensure that there are no detrimental effects on the material's 
fitness for use.  Wherever possible, food grade lubricants and oils should be used. (5.14) 
 
Closed or contained equipment should be used whenever appropriate.  Where open equipment is 
used, or equipment is opened, appropriate precautions should be taken to minimize the risk of 
contamination. (5.15) 
 
A set of current drawings should be maintained for equipment and critical installations (e.g., 
instrumentation and utility systems). (5.16) 
 
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B.  Equipment Maintenance and Cleaning (5.2) 
 
Schedules and procedures (including assignment of responsibility) should be established for the 
preventative maintenance of equipment. (5.20) 
 
Written procedures should be established for cleaning equipment and its subsequent release for 
use in the manufacture of intermediates and APIs.  Cleaning procedures should contain sufficient 
details to enable operators to clean each type of equipment in a reproducible and effective 
manner.  These procedures should include the following: (5.21) 
 
  Assignment of responsibility for cleaning of equipment  
  Cleaning schedules, including, where appropriate, sanitizing schedules 
  A complete description of the methods and materials, including dilution of cleaning 
agents used to clean equipment  
  When appropriate, instructions for disassembling and reassembling each article of 
equipment to ensure proper cleaning 
  Instructions for the removal or obliteration of previous batch identification 
  Instructions for the protection of clean equipment from contamination prior to use 
  Inspection of equipment for cleanliness immediately before use, if practical 
  Establishing the maximum time that may elapse between the completion of 
processing and equipment cleaning, when appropriate 
 
Equipment and utensils should be cleaned, stored, and, where appropriate, sanitized or sterilized 
to prevent contamination or carry-over of a material that would alter the quality of the 
intermediate or API beyond the official or other established specifications. (5.22)   
 
Where equipment is assigned to continuous production or campaign production of successive 
batches of the same intermediate or API, equipment should be cleaned at appropriate intervals to 
prevent build-up and carry-over of contaminants (e.g., degradants or objectionable levels of 
microorganisms). (5.23) 
 
Nondedicated equipment should be cleaned between production of different materials to prevent 
cross-contamination.  (5.24) 
 
Acceptance criteria for residues and the choice of cleaning procedures and cleaning agents should 
be defined and justified. (5.25) 
 
Equipment should be identified as to its contents and its cleanliness status by appropriate means. 
(5.26) 
 
C.  Calibration (5.3) 
 
Control, weighing, measuring, monitoring, and testing equipment critical for ensuring the quality 
of intermediates or APIs should be calibrated according to written procedures and an established 
schedule.  (5.30) 
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  Contains Nonbinding Recommendations 
   
 
Equipment calibrations should be performed using standards traceable to certified standards, if 
they exist.  (5.31) 
 
Records of these calibrations should be maintained. (5.32) 
 
The current calibration status of critical equipment should be known and verifiable. (5.33) 
 
Instruments that do not meet calibration criteria should not be used. (5.34) 
 
Deviations from approved standards of calibration on critical instruments should be investigated 
to determine if these could have had an effect on the quality of the intermediate(s) or API(s) 
manufactured using this equipment since the last successful calibration. (5.35) 
 
D.  Computerized Systems (5.4)  
 
GMP-related computerized systems should be validated.  The depth and scope of validation 
depends on the diversity, complexity, and criticality of the computerized application. (5.40) 
 
Appropriate installation and operational qualifications should demonstrate the suitability of 
computer hardware and software to perform assigned tasks. (5.41) 
 
Commercially available software that has been qualified does not require the same level of 
testing.  If an existing system was not validated at time of installation, a retrospective validation 
could be conducted if appropriate documentation is available. (5.42) 
 
Computerized systems should have sufficient controls to prevent unauthorized access or changes 
to data. There should be controls to prevent omissions in data (e.g., system turned off and data 
not captured). There should be a record of any data change made, the previous entry, who made 
the change, and when the change was made.  (5.43) 
 
Written procedures should be available for the operation and maintenance of computerized 
systems.   (5.44) 
 
Where critical data are being entered manually, there should be an additional check on the 
accuracy of the entry.  This can be done by a second operator or by the system itself. (5.45) 
 
Incidents related to computerized systems that could affect the quality of intermediates or APIs 
or the reliability of records or test results should be recorded and investigated. (5.46) 
 
Changes to computerized systems should be made according to a change procedure and should 
be formally authorized, documented, and tested.  Records should be kept of all changes, 
including modifications and enhancements made to the hardware, software, and any other critical 
component of the system. These records should demonstrate that the system is maintained in a 
validated state. (5.47) 
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  Contains Nonbinding Recommendations 
   
 
If system breakdowns or failures would result in the permanent loss of records, a back-up system 
should be provided.  A means of ensuring data protection should be established for all 
computerized systems. (5.48) 
 
Data can be recorded by a second means in addition to the computer system.  (5.49) 
 
 
VI.  DOCUMENTATION AND RECORDS (6) 
 
A.  Documentation System and Specifications (6.1) 
 
All documents related to the manufacture of intermediates or APIs should be prepared, reviewed, 
approved, and distributed according to written procedures.  Such documents can be in paper or 
electronic form. (6.10) 
 
The issuance, revision, superseding, and withdrawal of all documents should be controlled by 
maintaining revision histories. (6.11) 
 
A procedure should be established for retaining all appropriate documents (e.g., development 
history reports, scale-up reports, technical transfer reports, process validation reports, training 
records, production records, control records, and distribution records).  The retention periods for 
these documents should be specified. (6.12) 
 
All production, control, and distribution records should be retained for at least 1 year after the 
expiry date of the batch.  For APIs with retest dates, records should be retained for at least 3 
years after the batch is completely distributed. (6.13) 
 
When entries are made in records, these should be made indelibly in spaces provided for such 
entries, directly after performing the activities, and should identify the person making the entry.  
Corrections to entries should be dated and signed and leave the original entry still legible. (6.14) 
 
During the retention period, originals or copies of records should be readily available at the 
establishment where the activities described in such records occurred.  Records that can be 
promptly retrieved from another location by electronic or other means are acceptable. (6.15) 
 
Specifications, instructions, procedures, and records can be retained either as originals or as true 
copies such as photocopies, microfilm, microfiche, or other accurate reproductions of the original 
records.  Where reduction techniques such as microfilming or electronic records are used, 
suitable retrieval equipment and a means to produce a hard copy should be readily available. 
(6.16) 
 
Specifications should be established and documented for raw materials, intermediates where 
necessary, APIs, and labeling and packaging materials.  In addition, specifications may be 
appropriate for certain other materials, such as process aids, gaskets, or other materials used 
    15     
  Contains Nonbinding Recommendations 
   
during the production of intermediates or APIs that could critically affect quality.  Acceptance 
criteria should be established and documented for in-process controls. (6.17) 
 
If electronic signatures are used on documents, they should be authenticated and secure.  (6.18) 
 
B.  Equipment Cleaning and Use Record (6.2) 
 
Records of major equipment use, cleaning, sanitation, and/or sterilization and maintenance 
should show the date, time (if appropriate), product, and batch number of each batch processed in 
the equipment and the person who performed the cleaning and maintenance. (6.20) 
 
If equipment is dedicated to manufacturing one intermediate or API, individual equipment 
records are not necessary if batches of the intermediate or API follow in traceable sequence.  In 
cases where dedicated equipment is employed, the records of cleaning, maintenance, and use can 
be part of the batch record or maintained separately. (6.21) 
 
C.  Records of Raw Materials, Intermediates, API Labeling and Packaging Materials 
(6.3) 
 
Records should be maintained including the following: (6.30) 
 
  The name of the manufacturer, identity, and quantity of each shipment of each batch of 
raw materials, intermediates, or labeling and packaging materials for API's; the name of 
the supplier; the supplier's control number(s), if known, or other identification number; 
the number allocated on receipt; and the date of receipt 
 
  The results of any test or examination performed and the conclusions derived from this 
 
  Records tracing the use of materials 
 
  Documentation of the examination and review of API labeling and packaging materials 
for conformity with established specifications 
 
  The final decision regarding rejected raw materials, intermediates, or API labeling and 
packaging materials 
 
Master (approved) labels should be maintained for comparison to issued labels.  (6.31) 
 
D.  Master Production Instructions (Master Production and Control Records) (6.4) 
 
To ensure uniformity from batch to batch, master production instructions for each intermediate 
and API should be prepared, dated, and signed by one person and independently checked, dated, 
and signed by a person in the quality unit(s). (6.40) 
 
Master production instructions should include the following: (6.41) 
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  Contains Nonbinding Recommendations 
   
  The name of the intermediate or API being manufactured and an identifying document 
reference code, if applicable 
  A complete list of raw materials and intermediates designated by names or codes 
sufficiently specific to identify any special quality characteristics 
  An accurate statement of the quantity or ratio of each raw material or intermediate to be 
used, including the unit of measure.  Where the quantity is not fixed, the calculation for 
each batch size or rate of production should be included.  Variations to quantities should 
be included where they are justified 
  The production location and major production equipment to be used 
  Detailed production instructions, including the: 
 - sequences to be followed  
 - ranges of  process parameters to be used    
- sampling instructions and in-process controls with their acceptance criteria, where           
appropriate      
- time limits for completion of individual processing steps and/or the total process, where 
appropriate 
 - expected yield ranges at appropriate phases of processing or time 
  Where appropriate, special notations and precautions to be followed, or cross-references 
to these  
  The instructions for storage of the intermediate or API to ensure its suitability for use, 
including the labelling and packaging materials and special storage conditions with time 
limits, where appropriate. 
 
E.  Batch Production Records (Batch Production and Control Records) (6.5) 
 
Batch production records should be prepared for each intermediate and API and should include 
complete information relating to the production and control of each batch. The batch production 
record should be checked before issuance to ensure that it is the correct version and a legible 
accurate reproduction of the appropriate master production instruction.  If the batch production 
record is produced from a separate part of the master document, that document should include a 
reference to the current master production instruction being used.  (6.50) 
 
These records should be numbered with a unique batch or identification number, dated and 
signed when issued.  In continuous production, the product code together with the date and time 
can serve as the unique identifier until the final number is allocated. (6.51) 
 
Documentation of completion of each significant step in the batch production records (batch 
production and control records) should include the following: (6.52) 
  Dates and, when appropriate, times 
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  Contains Nonbinding Recommendations 
   
  Identity of major equipment (e.g., reactors, driers, mills, etc.) used 
  Specific identification of each batch, including weights, measures, and batch numbers of 
raw materials, intermediates, or any reprocessed materials used during manufacturing 
  Actual results recorded for critical process parameters  
  Any sampling performed 
  Signatures of the persons performing and directly supervising or checking each critical 
step in the operation 
  In-process and laboratory test results 
  Actual yield at appropriate phases or times 
  Description of packaging and label for intermediate or API 
  Representative label of API or intermediate if made commercially available  
  Any deviation noted, its evaluation, investigation conducted (if appropriate) or reference 
to that investigation if stored separately 
  Results of release testing 
 
Written procedures should be established and followed for investigating critical deviations or the 
failure of a batch of intermediate or API to meet specifications. The investigation should extend 
to other batches that may have been associated with the specific failure or deviation. (6.53) 
 
F.  Laboratory Control Records (6.6) 
 
Laboratory control records should include complete data derived from all tests conducted to 
ensure compliance with established specifications and standards, including examinations and 
assays, as follows: (6.60)  
 
  A description of samples received for testing, including the material name or source, 
batch number or other distinctive code, date sample was taken, and, where appropriate, 
the quantity and date the sample was received for testing  
  A statement of or reference to each test method used 
  A statement of the weight or measure of sample used for each test as described by the 
method; data on or cross-reference to the preparation and testing of reference standards, 
reagents and standard solutions 
  A complete record of all raw data generated during each test, in addition to graphs, charts 
and spectra from laboratory instrumentation, properly identified to show the specific 
material and batch tested 
  A record of all calculations performed in connection with the test, including, for example, 
units of measure, conversion factors, and equivalency factors 
  A statement of the test results and how they compare with established acceptance criteria 
  The signature of the person who performed each test and the date(s) the tests were 
performed 
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  Contains Nonbinding Recommendations 
   
  The date and signature of a second person showing that the original records have been 
reviewed for accuracy, completeness, and compliance with established standards 
 
Complete records should also be maintained for the following: (6.61) 
 
  Any modifications to an established analytical method  
  Periodic calibration of laboratory instruments, apparatus, gauges, and recording devices 
  All stability testing performed on APIs 
  Out-of-specification (OOS) investigations 
 
G.  Batch Production Record Review (6.7) 
 
Written procedures should be established and followed for the review and approval of batch 
production and laboratory control records, including packaging and labeling, to determine 
compliance of the intermediate or API with established specifications before a batch is released 
or distributed. (6.70) 
 
Batch production and laboratory control records of critical process steps should be reviewed and 
approved by the quality unit(s) before an API batch is released or distributed.  Production and 
laboratory control records of noncritical process steps can be reviewed by qualified production 
personnel or other units following procedures approved by the quality unit(s). (6.71) 
 
All deviation, investigation, and OOS reports should be reviewed as part of the batch record 
review before the batch is released. (6.72) 
 
The quality unit(s) can delegate to the production unit the responsibility and authority for release 
of intermediates, except for those shipped outside the control of the manufacturing company. 
(6.73) 
 
 
VII.  MATERIALS MANAGEMENT (7) 
 
A.  General Controls (7.1) 
 
There should be written procedures describing the receipt, identification, quarantine, storage, 
handling, sampling, testing, and approval or rejection of materials. (7.10) 
 
Manufacturers of intermediates and/or APIs should have a system for evaluating the suppliers of 
critical materials. (7.11) 
 
Materials should be purchased against an agreed specification, from a supplier, or suppliers, 
approved by the quality unit(s).  (7.12) 
 
If the supplier of a critical material is not the manufacturer of that material, the name and address 
of that manufacturer should be known by the intermediate and/or API manufacturer. (7.13)  
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  Contains Nonbinding Recommendations 
   
 
Changing the source of supply of critical raw materials should be treated according to Section 13, 
Change Control. (7.14) 
 
B.  Receipt and Quarantine (7.2) 
 
Upon receipt and before acceptance, each container or grouping of containers of materials should 
be examined visually for correct labeling (including correlation between the name used by the 
supplier and the in-house name, if these are different), container damage, broken seals and 
evidence of tampering or contamination. Materials should be held under quarantine until they 
have been sampled, examined, or tested, as appropriate, and released for use. (7.20) 
 
Before incoming materials are mixed with existing stocks (e.g., solvents or stocks in silos), they 
should be identified as correct, tested, if appropriate, and released.  Procedures should be 
available to prevent discharging incoming materials wrongly into the existing stock. (7.21) 
 
If bulk deliveries are made in nondedicated tankers, there should be assurance of no cross-
contamination from the tanker.  Means of providing this assurance could include one or more of 
the following: (7.22) 
 
  certificate of cleaning 
  testing for trace impurities 
  audit of the supplier 
 
Large storage containers and their attendant manifolds, filling, and discharge lines should be 
appropriately identified. (7.23) 
 
Each container or grouping of containers (batches) of materials should be assigned and identified 
with a distinctive code, batch, or receipt number.  This number should be used in recording the 
disposition of each batch.  A system should be in place to identify the status of each batch. (7.24) 
 
C.  Sampling and Testing of Incoming Production Materials (7.3) 
 
At least one test to verify the identity of each batch of material should be conducted, with the 
exception of the materials described below.  A supplier's certificate of analysis can be used in 
place of performing other tests, provided that the manufacturer has a system in place to evaluate 
suppliers. (7.30) 
 
Supplier approval should include an evaluation that provides adequate evidence (e.g., past quality 
history) that the manufacturer can consistently provide material meeting specifications.  
Complete analyses should be conducted on at least three batches before reducing in-house 
testing.  However, as a minimum, a complete analysis should be performed at appropriate 
intervals and compared with the certificates of analysis. Reliability of certificates of analysis 
should be checked at regular intervals. (7.31) 
 
    20     
  Contains Nonbinding Recommendations 
   
Processing aids, hazardous or highly toxic raw materials, other special materials, or materials 
transferred to another unit within the companys control do not need to be tested if the 
manufacturers certificate of analysis is obtained, showing that these raw materials conform to 
established specifications. Visual examination of containers, labels, and recording of batch 
numbers should help in establishing the identity of these materials.  The lack of on-site testing for 
these materials should be justified and documented. (7.32) 
 
Samples should be representative of the batch of material from which they are taken.  Sampling 
methods should specify the number of containers to be sampled, which part of the container to 
sample, and the amount of material to be taken from each container.  The number of containers to 
sample and the sample size should be based on a sampling plan that takes into consideration the 
criticality of the material, material variability, past quality history of the supplier, and the 
quantity needed for analysis. (7.33) 
 
Sampling should be conducted at defined locations and by procedures designed to prevent 
contamination of the material sampled and contamination of other materials. (7.34) 
 
Containers from which samples are withdrawn should be opened carefully and subsequently 
reclosed.  They should be marked to indicate that a sample has been taken. (7.35) 
 
D.  Storage (7.4) 
 
Materials should be handled and stored in a manner to prevent degradation, contamination, and 
cross-contamination. (7.40) 
 
Materials stored in fiber drums, bags, or boxes should be stored off the floor and, when 
appropriate, suitably spaced to permit cleaning and inspection.  (7.41) 
 
Materials should be stored under conditions and for a period that have no adverse effect on their 
quality, and should normally be controlled so that the oldest stock is used first.  (7.42) 
 
Certain materials in suitable containers can be stored outdoors, provided identifying labels 
remain legible and containers are appropriately cleaned before opening and use. (7.43) 
 
Rejected materials should be identified and controlled under a quarantine system designed to 
prevent their unauthorized use in manufacturing. (7.44) 
 
E.  Re-evaluation (7.5) 
 
Materials should be re-evaluated, as appropriate, to determine their suitability for use (e.g., after 
prolonged storage or exposure to heat or humidity). (7.50) 
 
 
VIII.  PRODUCTION AND IN-PROCESS CONTROLS (8) 
 
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A.  Production Operations (8.1) 
 
Raw materials for intermediate and API manufacturing should be weighed or measured under 
appropriate conditions that do not affect their suitability for use. Weighing and measuring 
devices should be of suitable accuracy for the intended use.  (8.10) 
 
If a material is subdivided for later use in production operations, the container receiving the 
material should be suitable and should be so identified that the following information is 
available: (8.11) 
 
  Material name and/or item code 
  Receiving or control number 
  Weight or measure of material in the new container 
  Re-evaluation or retest date if appropriate 
 
Critical weighing, measuring, or subdividing operations should be witnessed or subjected to an 
equivalent control.  Prior to use, production personnel should verify that the materials are those 
specified in the batch record for the intended intermediate or API. (8.12) 
 
Other critical activities should be witnessed or subjected to an equivalent control. (8.13) 
 
Actual yields should be compared with expected yields at designated steps in the production 
process.  Expected yields with appropriate ranges should be established based on previous 
laboratory, pilot scale, or manufacturing data.  Deviations in yield associated with critical process 
steps should be investigated to determine their impact or potential impact on the resulting quality 
of affected batches. (8.14) 
 
Any deviation should be documented and explained.  Any critical deviation should be 
investigated. (8.15) 
 
The processing status of major units of equipment should be indicated either on the individual 
units of equipment or by appropriate documentation, computer control systems, or alternative 
means. (8.16) 
 
Materials to be reprocessed or reworked should be appropriately controlled to prevent 
unauthorized use. (8.17) 
 
B.  Time Limits (8.2) 
 
If time limits are specified in the master production instruction (see 6.40), these time limits 
should be met to ensure the quality of intermediates and APIs. Deviations should be documented 
and evaluated.  Time limits may be inappropriate when processing to a target value (e.g., pH 
adjustment, hydrogenation, drying to predetermined specification) because completion of 
reactions or processing steps are determined by in-process sampling and testing. (8.20) 
 
    22     
  Contains Nonbinding Recommendations 
   
Intermediates held for further processing should be stored under appropriate conditions to ensure 
their suitability for use. (8.21) 
 
C.  In-process Sampling and Controls (8.3) 
 
Written procedures should be established to monitor the progress and control the performance of 
processing steps that cause variability in the quality characteristics of intermediates and APIs.  
In-process controls and their acceptance criteria should be defined based on the information 
gained during the developmental stage or from historical data.  (8.30) 
 
The acceptance criteria and type and extent of testing can depend on the nature of the 
intermediate or API being manufactured, the reaction or process step being conducted, and the 
degree to which the process introduces variability in the products quality.  Less stringent in-
process controls may be appropriate in early processing steps, whereas tighter controls may be 
appropriate for later processing steps (e.g., isolation and purification steps). (8.31) 
 
Critical in-process controls (and critical process monitoring), including control points and 
methods, should be stated in writing and approved by the quality unit(s). (8.32)   
 
In-process controls can be performed by qualified production department personnel and the 
process adjusted without prior quality unit(s) approval if the adjustments are made within pre-
established limits approved by the quality unit(s).  All tests and results should be fully 
documented as part of the batch record. (8.33) 
 
Written procedures should describe the sampling methods for in-process materials, intermediates, 
and APIs.  Sampling plans and procedures should be based on scientifically sound sampling 
practices. (8.34) 
 
In-process sampling should be conducted using procedures designed to prevent contamination of 
the sampled material and other intermediates or APIs.  Procedures should be established to 
ensure the integrity of samples after collection.  (8.35) 
 
Out-of-specification (OOS) investigations are not normally needed for in-process tests that are 
performed for the purpose of monitoring and/or adjusting the process. (8.36) 
 
D.  Blending Batches of Intermediates or APIs (8.4) 
 
For the purpose of this document, blending is defined as the process of combining materials 
within the same specification to produce a homogeneous intermediate or API.  In-process mixing 
of fractions from single batches  (e.g., collecting several centrifuge loads from a single 
crystallization batch) or combining fractions from several batches for further processing is 
considered to be part of the production process and is not considered to be blending. (8.40) 
 
Out-of-specification batches should not be blended with other batches for the purpose of meeting 
specifications.  Each batch incorporated into the blend should have been manufactured using an 
    23     
  Contains Nonbinding Recommendations 
   
established process and should have been individually tested and found to meet appropriate 
specifications prior to blending. (8.41) 
  
Acceptable blending operations include, but are not limited to: (8.42) 
 
  Blending of small batches to increase batch size 
  Blending of tailings (i.e., relatively small quantities of isolated material) from batches of 
the same intermediate or API to form a single batch 
 
Blending processes should be adequately controlled and documented, and the blended batch 
should be tested for conformance to established specifications, where appropriate. (8.43) 
 
The batch record of the blending process should allow traceability back to the individual batches 
that make up the blend. (8.44) 
 
Where physical attributes of the API are critical (e.g., APIs intended for use in solid oral dosage 
forms or suspensions), blending operations should be validated to show homogeneity of the 
combined batch.  Validation should include testing of critical attributes (e.g., particle size 
distribution, bulk density, and tap density) that may be affected by the blending process. (8.45) 
 
If the blending could adversely affect stability, stability testing of the final blended batches 
should be performed. (8.46) 
 
The expiry or retest date of the blended batch should be based on the manufacturing date of the 
oldest tailings or batch in the blend. (8.47) 
 
E.  Contamination Control (8.5) 
  
Residual materials can be carried over into successive batches of the same intermediate or API if 
there is adequate control.  Examples include residue adhering to the wall of a micronizer, 
residual layer of damp crystals remaining in a centrifuge bowl after discharge, and incomplete 
discharge of fluids or crystals from a processing vessel upon transfer of the material to the next 
step in the process.  Such carryover should not result in the carryover of degradants or microbial 
contamination that may adversely alter the established API impurity profile. (8.50) 
 
Production operations should be conducted in a manner that prevents contamination of 
intermediates or APIs by other materials. (8.51) 
 
Precautions to avoid contamination should be taken when APIs are handled after purification. 
(8.52) 
 
 
IX.  PACKAGING AND IDENTIFICATION LABELING OF APIs AND 
INTERMEDIATES (9) 
 
    24     
  Contains Nonbinding Recommendations 
   
A.  General      (9.1) 
 
There should be written procedures describing the receipt, identification, quarantine, sampling, 
examination, and/or testing, release, and handling of packaging and labeling materials. (9.10) 
 
Packaging and labeling materials should conform to established specifications.  Those that do not 
comply with such specifications should be rejected to prevent their use in operations for which 
they are unsuitable. (9.11) 
  
Records should be maintained for each shipment of labels and packaging materials showing 
receipt, examination, or testing, and whether accepted or rejected. (9.12) 
 
B.  Packaging Materials (9.2) 
 
Containers should provide adequate protection against deterioration or contamination of the 
intermediate or API that may occur during transportation and recommended storage. (9.20) 
 
Containers should be clean and, where indicated by the nature of the intermediate or API, 
sanitized to ensure that they are suitable for their intended use.  These containers should not be 
reactive, additive, or absorptive so as to alter the quality of the intermediate or API beyond the 
specified limits. (9.21) 
 
If containers are reused, they should be cleaned in accordance with documented procedures, and 
all previous labels should be removed or defaced. (9.22) 
 
C.  Label Issuance and Control (9.3) 
 
Access to the label storage areas should be limited to authorized personnel. (9.30) 
 
Procedures should be established to reconcile the quantities of labels issued, used, and returned 
and to evaluate discrepancies found between the number of containers labeled and the number of 
labels issued. Such discrepancies should be investigated, and the investigation should be 
approved by the quality unit(s). (9.31) 
 
All excess labels bearing batch numbers or other batch-related printing should be destroyed.  
Returned labels should be maintained and stored in a manner that prevents mix-ups and provides 
proper identification. (9.32) 
 
Obsolete and out-dated labels should be destroyed. (9.33) 
 
Printing devices used to print labels for packaging operations should be controlled to ensure that 
all imprinting conforms to the print specified in the batch production record.  (9.34) 
 
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Printed labels issued for a batch should be carefully examined for proper identity and conformity 
to specifications in the master production record.  The results of this examination should be 
documented. (9.35) 
 
A printed label representative of those used should be included in the batch production record. 
(9.36) 
 
D.  Packaging and Labeling Operations (9.4) 
 
There should be documented procedures designed to ensure that correct packaging materials and 
labels are used. (9.40) 
 
Labeling operations should be designed to prevent mix-ups.  There should be physical or spatial 
separation from operations involving other intermediates or APIs. (9.41) 
 
Labels used on containers of intermediates or APIs should indicate the name or identifying code, 
batch number, and storage conditions when such information is critical to ensure the quality of 
intermediate or API.   (9.42) 
 
If the intermediate or API is intended to be transferred outside the control of the manufacturers 
material management system, the name and address of the manufacturer, quantity of contents, 
special transport conditions, and any special legal requirements should also be included on the 
label.  For intermediates or APIs with an expiry date, the expiry date should be indicated on the 
label and certificate of analysis.  For intermediates or APIs with a retest date, the retest date 
should be indicated on the label and/or certificate of analysis.  (9.43) 
 
Packaging and labeling facilities should be inspected immediately before use to ensure that all 
materials not needed for the next packaging operation have been removed.  This examination 
should be documented in the batch production records, the facility log, or other documentation 
system.  (9.44) 
 
Packaged and labeled intermediates or APIs should be examined to ensure that containers and 
packages in the batch have the correct label.  This examination should be part of the packaging 
operation.   Results of these examinations should be recorded in the batch production or control 
records. (9.45) 
 
Intermediate or API containers that are transported outside of the manufacturer's control should 
be sealed in a manner such that, if the seal is breached or missing, the recipient will be alerted to 
the possibility that the contents may have been altered. (9.46) 
 
 
X.  STORAGE AND DISTRIBUTION (10) 
   
A.  Warehousing Procedures (10.1) 
 
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Facilities should be available for the storage of all materials under appropriate conditions (e.g., 
controlled temperature and humidity when necessary). Records should be maintained of these 
conditions if they are critical for the maintenance of material characteristics. (10.10) 
 
Unless there is an alternative system to prevent the unintentional or unauthorized use of 
quarantined, rejected, returned, or recalled materials, separate storage areas should be assigned 
for their temporary storage until the decision as to their future use has been made. (10.11) 
 
B.  Distribution Procedures (10.2) 
 
APIs and intermediates should only be released for distribution to third parties after they have 
been released by the quality unit(s).  APIs and intermediates can be transferred under quarantine 
to another unit under the companys control when authorized by the quality unit(s) and if 
appropriate controls and documentation are in place. (10.20) 
 
APIs and intermediates should be transported in a manner that does not adversely affect their 
quality. (10.21) 
 
Special transport or storage conditions for an API or intermediate should be stated on the label. 
(10.22) 
 
The manufacturer should ensure that the contract acceptor (contractor) for transportation of the 
API or intermediate knows and follows the appropriate transport and storage conditions. (10.23) 
 
A system should be in place by which the distribution of each batch of intermediate and/or API 
can be readily determined to permit its recall. (10.24) 
 
 
XI.  LABORATORY CONTROLS (11) 
 
A.  General Controls (11.1) 
 
The independent quality unit(s) should have at its disposal adequate laboratory facilities. (11.10) 
 
There should be documented procedures describing sampling, testing, approval, or rejection of 
materials and recording and storage of laboratory data.  Laboratory records should be maintained 
in accordance with Section 6.6. (11.11) 
 
All specifications, sampling plans, and test procedures should be scientifically sound and 
appropriate to ensure that raw materials, intermediates, APIs, and labels and packaging materials 
conform to established standards of quality and/or purity.  Specifications and test procedures 
should be consistent with those included in the registration/filing.   There can be specifications in 
addition to those in the registration/filing.  Specifications, sampling plans, and test procedures, 
including changes to them, should be drafted by the appropriate organizational unit and reviewed 
and approved by the quality unit(s). (11.12) 
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Appropriate specifications should be established for APIs in accordance with accepted standards 
and consistent with the manufacturing process. The specifications should include control of 
impurities (e.g., organic impurities, inorganic impurities, and residual solvents).  If the API has a 
specification for microbiological purity, appropriate action limits for total microbial counts and 
objectionable organisms should be established and met.  If the API has a specification for 
endotoxins, appropriate action limits should be established and met. (11.13) 
 
Laboratory controls should be followed and documented at the time of performance. Any 
departures from the above-described procedures should be documented and explained. (11.14) 
 
Any out-of-specification result obtained should be investigated and documented according to a 
procedure. This procedure should include analysis of the data, assessment of whether a 
significant problem exists, allocation of the tasks for corrective actions, and conclusions.  Any 
resampling and/or retesting after OOS results should be performed according to a documented 
procedure. (11.15) 
 
Reagents and standard solutions should be prepared and labeled following written procedures.  
Use by dates should be applied, as appropriate, for analytical reagents or standard solutions.  
(11.16) 
 
Primary reference standards should be obtained, as appropriate, for the manufacture of APIs.  
The source of each primary reference standard should be documented.  Records should be 
maintained of each primary reference standards storage and use in accordance with the 
suppliers recommendations.  Primary reference standards obtained from an officially recognized 
source are normally used without testing if stored under conditions consistent with the suppliers 
recommendations. (11.17) 
 
Where a primary reference standard is not available from an officially recognized source, an in-
house primary standard should be established.  Appropriate testing should be performed to 
establish fully the identity and purity of the primary reference standard.  Appropriate 
documentation of this testing should be maintained. (11.18) 
 
Secondary reference standards should be appropriately prepared, identified, tested, approved, and 
stored.  The suitability of each batch of secondary reference standard should be determined prior 
to first use by comparing against a primary reference standard.  Each batch of secondary 
reference standard should be periodically requalified in accordance with a written protocol. 
(11.19) 
 
B.  Testing of Intermediates and APIs (11.2) 
 
For each batch of intermediate and API, appropriate laboratory tests should be conducted to 
determine conformance to specifications. (11.20) 
 
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An impurity profile describing the identified and unidentified impurities present in a typical 
batch produced by a specific controlled production process should normally be established for 
each API.  The impurity profile should include the identity or some qualitative analytical 
designation (e.g., retention time), the range of each impurity observed, and classification of each 
identified impurity (e.g., inorganic, organic, solvent).  The impurity profile is normally dependent 
upon the production process and origin of the API.  Impurity profiles are normally not necessary 
for APIs from herbal or animal tissue origin.  Biotechnology considerations are covered in ICH 
guidance Q6B. (11.21) 
 
The impurity profile should be compared at appropriate intervals against the impurity profile in 
the regulatory submission or compared against historical data to detect changes to the API 
resulting from modifications in raw materials, equipment operating parameters, or the production 
process. (11.22) 
 
Appropriate microbiological tests should be conducted on each batch of intermediate and API 
where microbial quality is specified. (11.23) 
 
C.  Validation of Analytical Procedures - See Section 12. (11.3) 
 
D.  Certificates of Analysis (11.4) 
 
Authentic certificates of analysis should be issued for each batch of intermediate or API on 
request. (11.40) 
 
Information on the name of the intermediate or API including, where appropriate, its grade, the 
batch number, and the date of release should be provided on the certificate of analysis.  For 
intermediates or APIs with an expiry date, the expiry date should be provided on the label and 
certificate of analysis. For intermediates or APIs with a retest date, the retest date should be 
indicated on the label and/or certificate of analysis. (11.41) 
 
The certificate should list each test performed in accordance with compendial or customer 
requirements, including the acceptance limits, and the numerical results obtained (if test results 
are numerical). (11.42) 
 
Certificates should be dated and signed by authorized personnel of the quality unit(s) and should 
show the name, address, and telephone number of the original manufacturer.  Where the analysis 
has been carried out by a repacker or reprocessor, the certificate of analysis should show the 
name, address, and telephone number of the repacker/reprocessor and reference the name of the 
original manufacturer. (11.43) 
 
If new certificates are issued by or on behalf of repackers/reprocessors, agents or brokers, these 
certificates should show the name, address and telephone number of the laboratory that 
performed the analysis. They should also contain a reference to the name and address of the 
original manufacturer and to the original batch certificate, a copy of which should be attached. 
(11.44) 
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E.  Stability Monitoring of APIs (11.5) 
 
A documented, on-going testing program should be established to monitor the stability 
characteristics of APIs, and the results should be used to confirm appropriate storage conditions 
and retest or expiry dates. (11.50) 
 
The test procedures used in stability testing should be validated and be stability indicating. 
(11.51) 
 
Stability samples should be stored in containers that simulate the market container. For example, 
if the API is marketed in bags within fiber drums, stability samples can be packaged in bags of 
the same material and in small-scale drums of similar or identical material composition to the 
market drums. (11.52) 
 
Normally, the first three commercial production batches should be placed on the stability 
monitoring program to confirm the retest or expiry date.  However, where data from previous 
studies show that the API is expected to remain stable for at least 2 years, fewer than three 
batches can be used. (11.53) 
 
Thereafter, at least one batch per year of API manufactured (unless none is produced that year) 
should be added to the stability monitoring program and tested at least annually to confirm the 
stability. (11.54) 
 
For APIs with short shelf-lives, testing should be done more frequently.  For example, for those 
biotechnological/biologic and other APIs with shelf-lives of one year or less, stability samples 
should be obtained and should be tested monthly for the first 3 months, and at 3-month intervals 
after that.  When data exist that confirm that the stability of the API is not compromised, 
elimination of specific test intervals (e.g., 9-month testing) can be considered.  (11.55) 
 
Where appropriate, the stability storage conditions should be consistent with the ICH guidances 
on stability. (11.56) 
 
F.  Expiry and Retest Dating (11.6) 
 
When an intermediate is intended to be transferred outside the control of the manufacturers 
material management system and an expiry or retest date is assigned, supporting stability 
information should be available (e.g., published data, test results). (11.60) 
 
An API expiry or retest date should be based on an evaluation of data derived from stability 
studies.  Common practice is to use a retest date, not an expiration date. (11.61) 
 
Preliminary API expiry or retest dates can be based on pilot scale batches if (1) the pilot batches 
employ a method of manufacture and procedure that simulates the final process to be used on a 
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commercial manufacturing scale and (2) the quality of the API represents the material to be made 
on a commercial scale. (11.62) 
 
A representative sample should be taken for the purpose of performing a retest. (11.63) 
 
G.  Reserve/Retention Samples (11.7) 
 
The packaging and holding of reserve samples is for the purpose of potential future evaluation of 
the quality of batches of API and not for future stability testing purposes. (11.70) 
 
Appropriately identified reserve samples of each API batch should be retained for 1 year after the 
expiry date of the batch assigned by the manufacturer, or for 3 years after distribution of the 
batch, whichever is  longer.  For APIs with retest dates, similar reserve samples should be 
retained for 3 years after the batch is completely distributed by the manufacturer. (11.71) 
 
The reserve sample should be stored in the same packaging system in which the API is stored or 
in one that is equivalent to or more protective than the marketed packaging system.  Sufficient 
quantities should be retained to conduct at least two full compendial analyses or, when there is no 
pharmacopoeial monograph, two full specification analyses. (11.72) 
 
 
XII.  VALIDATION (12) 
 
A.  Validation Policy (12.1) 
 
The company's overall policy, intentions, and approach to validation, including the validation of 
production processes, cleaning procedures, analytical methods, in-process control test 
procedures, computerized systems, and persons responsible for design, review, approval, and 
documentation of each validation phase, should be documented. (12.10) 
 
The critical parameters/attributes should normally be identified during the development stage or 
from historical data, and the necessary ranges for the reproducible operation should be defined.  
This should include the following: (12.11) 
 
  Defining the API in terms of its critical product attributes 
 
  Identifying process parameters that could affect the critical quality attributes of the API 
 
  Determining the range for each critical process parameter expected to be used during 
routine manufacturing and process control 
 
Validation should extend to those operations determined to be critical to the quality and purity of 
the API. (12.12) 
 
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B.  Validation Documentation (12.2) 
 
A written validation protocol should be established that specifies how validation of a particular 
process will be conducted.  The protocol should be reviewed and approved by the quality unit(s) 
and other designated units. (12.20) 
 
The validation protocol should specify critical process steps and acceptance criteria as well as the 
type of validation to be conducted (e.g., retrospective, prospective, concurrent) and the number of 
process runs. (12.21) 
 
A validation report that cross-references the validation protocol should be prepared, summarizing 
the results obtained, commenting on any deviations observed, and drawing the appropriate 
conclusions, including recommending changes to correct deficiencies. (12.22) 
 
Any variations from the validation protocol should be documented with appropriate justification. 
(12.23) 
 
C.  Qualification (12.3) 
 
Before initiating process validation activities, appropriate qualification of critical equipment and 
ancillary systems should be completed.  Qualification is usually carried out by conducting the 
following activities, individually or combined: (12.30) 
 
  Design Qualification (DQ): documented verification that the proposed design of the 
facilities, equipment, or systems is suitable for the intended purpose  
 
  Installation Qualification (IQ): documented verification that the equipment or systems, as 
installed or modified, comply with the approved design, the manufacturers 
recommendations and/or user requirements 
 
  Operational Qualification (OQ): documented verification that the equipment or systems, 
as installed or modified, perform as intended throughout the anticipated operating ranges 
 
  Performance Qualification (PQ): documented verification that the equipment and 
ancillary systems, as connected together, can perform effectively and reproducibly based 
on the approved process method and specifications 
 
D.  Approaches to Process Validation (12.4) 
 
Process Validation (PV) is the documented evidence that the process, operated within established 
parameters, can perform effectively and reproducibly to produce an intermediate or API meeting 
its predetermined specifications and quality attributes. (12.40) 
 
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There are three approaches to validation.  Prospective validation is the preferred approach, but 
there are situations where the other approaches can be used.  These approaches and their 
applicability are discussed here. (12.41) 
 
Prospective validation should normally be performed for all API processes as defined in 12.1.  
Prospective validation of an API process should be completed before the commercial distribution 
of the final drug product manufactured from that API. (12.42) 
 
Concurrent validation can be conducted when data from replicate production runs are unavailable 
because only a limited number of API batches have been produced, API batches are produced 
infrequently, or API batches are produced by a validated process that has been modified.  Prior to 
the completion of concurrent validation, batches can be released and used in final drug product 
for commercial distribution based on thorough monitoring and testing of the API batches. (12.43) 
 
An exception can be made for retrospective validation of well-established processes that have 
been used without significant changes to API quality due to changes in raw materials, equipment, 
systems, facilities, or the production process.  This validation approach may be used where the 
following apply: (12.44) 
 
1.  Critical quality attributes and critical process parameters have been identified  
 
2.  Appropriate in-process acceptance criteria and controls have been established  
 
3.  There have not been significant process/product failures attributable to causes other than 
operator error or equipment failures unrelated to equipment suitability  
 
4.  Impurity profiles have been established for the existing API  
 
Batches selected for retrospective validation should be representative of all batches produced 
during the review period, including any batches that failed to meet specifications, and should be 
sufficient in number to demonstrate process consistency.  Retained samples can be tested to 
obtain data to retrospectively validate the process. (12.45) 
 
E.  Process Validation Program (12.5) 
 
The number of process runs for validation should depend on the complexity of the process or the 
magnitude of the process change being considered.  For prospective and concurrent validation, 
three consecutive successful production batches should be used as a guide, but there may be 
situations where additional process runs are warranted to prove consistency of the process (e.g., 
complex API processes or API processes with prolonged completion times).  For retrospective 
validation, generally data from 10 to 30 consecutive batches should be examined to assess 
process consistency, but fewer batches can be examined if justified. (12.50) 
 
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Critical process parameters should be controlled and monitored during process validation studies. 
Process parameters unrelated to quality, such as variables controlled to minimize energy 
consumption or equipment use, need not be included in the process validation. (12.51) 
 
Process validation should confirm that the impurity profile for each API is within the limits 
specified.  The impurity profile should be comparable to, or better than, historical data and, 
where applicable, the profile determined during process development or for batches used for 
pivotal clinical and toxicological studies. (12.52) 
 
F.  Periodic Review of Validated Systems (12.6) 
 
Systems and processes should be periodically evaluated to verify that they are still operating in a 
valid manner. Where no significant changes have been made to the system or process, and a 
quality review confirms that the system or process is consistently producing material meeting its 
specifications, there is normally no need for revalidation. (12.60) 
 
G.  Cleaning Validation (12.7) 
 
Cleaning procedures should normally be validated.  In general, cleaning validation should be 
directed to situations or process steps where contamination or carryover of materials poses the 
greatest risk to API quality.  For example, in early production it may be unnecessary to validate 
equipment cleaning procedures where residues are removed by subsequent purification steps. 
(12.70) 
 
Validation of cleaning procedures should reflect actual equipment usage patterns.  If various 
APIs or intermediates are manufactured in the same equipment and the equipment is cleaned by 
the same process, a representative intermediate or API can be selected for cleaning validation.  
This selection should be based on the solubility and difficulty of cleaning and the calculation of 
residue limits based on potency, toxicity, and stability. (12.71) 
 
The cleaning validation protocol should describe the equipment to be cleaned, procedures, 
materials, acceptable cleaning levels, parameters to be monitored and controlled, and analytical 
methods.  The protocol should also indicate the type of samples to be obtained and how they are 
collected and labeled. (12.72) 
 
Sampling should include swabbing, rinsing, or alternative methods (e.g., direct extraction), as 
appropriate, to detect both insoluble and soluble residues.  The sampling methods used should be 
capable of quantitatively measuring levels of residues remaining on the equipment surfaces after 
cleaning.  Swab sampling may be impractical when product contact surfaces are not easily 
accessible due to equipment design and/or process limitations (e.g., inner surfaces of hoses, 
transfer pipes, reactor tanks with small ports or handling toxic materials, and small intricate 
equipment such as micronizers and microfluidizers). (12.73) 
 
Validated analytical methods having sensitivity to detect residues or contaminants should be 
used. The detection limit for each analytical method should be sufficiently sensitive to detect the 
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established acceptable level of the residue or contaminant.  The methods attainable recovery 
level should be established.  Residue limits should be practical, achievable, verifiable, and based 
on the most deleterious residue.  Limits can be established based on the minimum known 
pharmacological, toxicological, or physiological activity of the API or its most deleterious 
component. (12.74) 
 
Equipment cleaning/sanitation studies should address microbiological and endotoxin 
contamination for those processes where there is a need to reduce total microbiological count or 
endotoxins in the API, or other processes where such contamination could be of concern (e.g., 
non-sterile APIs used to manufacture sterile products). (12.75) 
 
Cleaning procedures should be monitored at appropriate intervals after validation to ensure that 
these procedures are effective when used during routine production. Equipment cleanliness can 
be monitored by analytical testing and visual examination, where feasible.  Visual inspection can 
allow detection of gross contamination concentrated in small areas that could otherwise go 
undetected by sampling and/or analysis. (12.76) 
 
H.  Validation of Analytical Methods (12.8) 
 
Analytical methods should be validated unless the method employed is included in the relevant 
pharmacopoeia or other recognized standard reference.  The suitability of all testing methods 
used should nonetheless be verified under actual conditions of use and documented. (12.80) 
 
Methods should be validated to include consideration of characteristics included within the ICH 
guidances on validation of analytical methods.  The degree of analytical validation performed 
should reflect the purpose of the analysis and the stage of the API production process. (12.81) 
 
Appropriate qualification of analytical equipment should be considered before initiating 
validation of analytical methods. (12.82) 
 
Complete records should be maintained of any modification of a validated analytical method.  
Such records should include the reason for the modification and appropriate data to verify that 
the modification produces results that are as accurate and reliable as the established method. 
(12.83) 
 
 
XIII.  CHANGE CONTROL (13) 
 
A formal change control system should be established to evaluate all changes that could affect 
the production and control of the intermediate or API.  (13.10) 
  
Written procedures should provide for the identification, documentation, appropriate review, and 
approval of changes in raw materials, specifications, analytical methods, facilities, support 
systems, equipment (including computer hardware), processing steps, labeling and packaging 
materials, and computer software. (13.11) 
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Any proposals for GMP relevant changes should be drafted, reviewed, and approved by the 
appropriate organizational units and reviewed and approved by the quality unit(s). (13.12) 
 
The potential impact of the proposed change on the quality of the intermediate or API should be 
evaluated.  A classification procedure may help in determining the level of testing, validation, 
and documentation needed to justify changes to a validated process. Changes can be classified 
(e.g., as minor or major) depending on the nature and extent of the changes, and the effects these 
changes may impart on the process. Scientific judgment should determine what additional testing 
and validation studies are appropriate to justify a change in a validated process. (13.13) 
 
When implementing approved changes, measures should be taken to ensure that all documents 
affected by the changes are revised. (13.14) 
 
After the change has been implemented, there should be an evaluation of the first batches 
produced or tested under the change.  (13.15) 
 
The potential for critical changes to affect established retest or expiry dates should be evaluated.  
If necessary, samples of the intermediate or API produced by the modified process can be placed 
on an accelerated stability program and/or can be added to the stability monitoring program. 
(13.16) 
 
Current dosage form manufacturers should be notified of changes from established production 
and process control procedures that can affect the quality of the API. (13.17) 
 
 
XIV.  REJECTION AND RE-USE OF MATERIALS (14) 
 
A.  Rejection (14.1) 
 
Intermediates and APIs failing to meet established specifications should be identified as such and 
quarantined.  These intermediates or APIs can be reprocessed or reworked as described below.  
The final disposition of rejected materials should be recorded. (14.10) 
 
B.  Reprocessing (14.2) 
 
Introducing an intermediate or API, including one that does not conform to standards or 
specifications, back into the process and reprocessing by repeating a crystallization step or other 
appropriate chemical or physical manipulation steps (e.g., distillation, filtration, chromatography, 
milling) that are part of the established manufacturing process is generally considered acceptable.  
However, if such reprocessing is used for a majority of batches, such reprocessing should be 
included as part of the standard manufacturing process. (14.20) 
 
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Continuation of a process step after an in-process control test has shown that the step is 
incomplete is considered to be part of the normal process.  This is not considered to be 
reprocessing.  (14.21) 
 
Introducing unreacted material back into a process and repeating a chemical reaction is 
considered to be reprocessing unless it is part of the established process. Such reprocessing 
should be preceded by careful evaluation to ensure that the quality of the intermediate or API is 
not adversely affected due to the potential formation of by-products and over-reacted materials. 
(14.22) 
 
C.  Reworking (14.3) 
 
Before a decision is taken to rework batches that do not conform to established standards or 
specifications, an investigation into the reason for nonconformance should be performed.  (14.30) 
 
Batches that have been reworked should be subjected to appropriate evaluation, testing, stability 
testing if warranted, and documentation to show that the reworked product is of equivalent 
quality to that produced by the original process.  Concurrent validation is often the appropriate 
validation approach for rework procedures.  This allows a protocol to define the rework 
procedure, how it will be carried out, and the expected results.  If there is only one batch to be 
reworked, a report can be written and the batch released once it is found to be acceptable. (14.31) 
 
Procedures should provide for comparing the impurity profile of each reworked batch against 
batches manufactured by the established process.  Where routine analytical methods are 
inadequate to characterize the reworked batch, additional methods should be used. (14.32) 
 
D.  Recovery of Materials and Solvents (14.4) 
 
Recovery (e.g., from mother liquor or filtrates) of reactants, intermediates, or the API is 
considered acceptable, provided that approved procedures exist for the recovery and the 
recovered materials meet specifications suitable for their intended use. (14.40) 
 
Solvents can be recovered and reused in the same processes or in different processes, provided 
that the recovery procedures are controlled and monitored to ensure that solvents meet 
appropriate standards before reuse or commingling with other approved materials. (14.41) 
 
Fresh and recovered solvents and reagents can be combined if adequate testing has shown their 
suitability for all manufacturing processes in which they may be used. (14.42) 
 
The use of recovered solvents, mother liquors, and other recovered materials should be 
adequately documented. (14.43) 
 
E.  Returns (14.5) 
 
Returned intermediates or APIs should be identified as such and quarantined. (14.50) 
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If the conditions under which returned intermediates or APIs have been stored or shipped before 
or during their return or the condition of their containers casts doubt on their quality, the returned 
intermediates or APIs should be reprocessed, reworked, or destroyed, as appropriate. (14.51) 
 
Records of returned intermediates or APIs should be maintained. For each return, documentation 
should include the following: (14.52) 
 
  Name and address of the consignee 
  Intermediate or API, batch number, and quantity returned 
  Reason for return 
  Use or disposal of the returned intermediate or API 
 
 
XV.  COMPLAINTS AND RECALLS (15) 
 
All quality-related complaints, whether received orally or in writing, should be recorded and 
investigated according to a written procedure. (15.10) 
 
Complaint records should include the following: (15.11) 
 
  Name and address of complainant 
  Name (and, where appropriate, title) and phone number of person submitting the 
complaint 
  Complaint nature (including name and batch number of the API) 
  Date complaint is received 
  Action initially taken (including dates and identity of person taking the action); 
  Any follow-up action taken 
  Response provided to the originator of complaint (including date response sent) 
  Final decision on intermediate or API batch or lot 
 
Records of complaints should be retained to evaluate trends, product-related frequencies, and 
severity with a view to taking additional, and if appropriate, immediate corrective action. (15.12) 
 
There should be a written procedure that defines the circumstances under which a recall of an 
intermediate or API should be considered. (15.13) 
 
The recall procedure should designate who should be involved in evaluating the information, 
how a recall should be initiated, who should be informed about the recall, and how the recalled 
material should be treated. (15.14) 
 
In the event of a serious or potentially life-threatening situation, local, national, and/or 
international authorities should be informed and their advice sought. (15.15) 
 
 
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XVI.  CONTRACT MANUFACTURERS (INCLUDING LABORATORIES) (16) 
 
All contract manufacturers (including laboratories) should comply with the GMP defined in this 
guidance.  Special consideration should be given to the prevention of cross-contamination and to 
maintaining traceability. (16.10) 
 
Companies should evaluate any contractors (including laboratories) to ensure GMP compliance 
of the specific operations occurring at the contractor sites. (16.11) 
 
There should be a written and approved contract or formal agreement between a company and its 
contractors that defines in detail the GMP responsibilities, including the quality measures, of 
each party. (16.12) 
 
A contract should permit a company to audit its contractor's facilities for compliance with GMP. 
(16.13) 
 
Where subcontracting is allowed, a contractor should not pass to a third party any of the work 
entrusted to it under the contract without the company's prior evaluation and approval of the 
arrangements. (16.14) 
 
Manufacturing and laboratory records should be kept at the site where the activity occurs and be 
readily available. (16.15) 
 
Changes in the process, equipment, test methods, specifications, or other contractual 
requirements should not be made unless the contract giver is informed and approves the changes. 
(16.16) 
 
 
XVII.  AGENTS, BROKERS, TRADERS, DISTRIBUTORS, REPACKERS, AND 
RELABELLERS (17) 
 
A.  Applicability (17.1) 
 
This section applies to any party other than the original manufacturer who may trade and/or take 
possession, repack, relabel, manipulate, distribute, or store an API or intermediate. (17.10) 
 
All agents, brokers, traders, distributors, repackers, and relabelers should comply with GMP as 
defined in this guidance. (17.11) 
 
B.  Traceability of Distributed APIs and Intermediates (17.2) 
 
Agents, brokers, traders, distributors, repackers, or relabelers should maintain complete 
traceability of APIs and intermediates that they distribute.  Documents that should be retained 
and available include the following: (17.20) 
 
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  Identity of original manufacturer 
  Address of original manufacturer 
  Purchase orders 
  Bills of lading (transportation documentation) 
  Receipt documents 
  Name or designation of API or intermediate 
  Manufacturers batch number 
  Transportation and distribution records 
  All authentic Certificates of Analysis, including those of the original manufacturer 
  Retest or expiry date 
 
C.  Quality Management (17.3) 
 
Agents, brokers, traders, distributors, repackers, or relabelers should establish, document and 
implement an effective system of managing quality, as specified in Section 2. (17.30) 
 
D.  Repackaging, Relabeling, and Holding of APIs and Intermediates (17.4) 
 
Repackaging, relabeling, and holding APIs and intermediates should be performed under 
appropriate GMP controls, as stipulated in this guidance, to avoid mix-ups and loss of API or 
intermediate identity or purity.  (17.40) 
 
Repackaging should be conducted under appropriate environmental conditions to avoid 
contamination and cross-contamination. (17.41) 
 
E.  Stability (17.5) 
 
Stability studies to justify assigned expiration or retest dates should be conducted if the API or 
intermediate is repackaged in a different type of container than that used by the API or 
intermediate manufacturer. (17.50) 
 
F.  Transfer of Information (17.6) 
 
Agents, brokers, distributors, repackers, or relabelers should transfer all quality or regulatory 
information received from an API or intermediate manufacturer to the customer, and from the 
customer to the API or intermediate manufacturer. (17.60)  
 
The agent, broker, trader, distributor, repacker, or relabeler who supplies the API or intermediate 
to the customer should provide the name of the original API or intermediate manufacturer and 
the batch number(s) supplied. (17.61) 
 
The agent should also provide the identity of the original API or intermediate manufacturer to 
regulatory authorities upon request. The original manufacturer can respond to the regulatory 
authority directly or through its authorized agents, depending on the legal relationship between 
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the authorized agents and the original API or intermediate manufacturer. (In this context 
authorized refers to authorized by the manufacturer.) (17.62) 
 
The specific guidance for certificate of analysis included in Section 11.4 should be met. (17.63) 
 
G.  Handling of Complaints and Recalls (17.7) 
 
Agents, brokers, traders, distributors, repackers, or relabelers should maintain records of 
complaints and recalls, as specified in Section 15, for all complaints and recalls that come to their 
attention.  (17.70) 
 
If the situation warrants, the agents, brokers, traders, distributors, repackers, or relabelers should 
review the complaint with the original API or intermediate manufacturer to determine whether 
any further action, either with other customers who may have received this API or intermediate 
or with the regulatory authority, or both, should be initiated. The investigation into the cause for 
the complaint or recall should be conducted and documented by the appropriate party. (17.71) 
 
Where a complaint is referred to the original API or intermediate manufacturer, the record 
maintained by the agents, brokers, traders, distributors, repackers, or relabelers should include 
any response received from the original API or intermediate manufacturer (including date and 
information provided). (17.72) 
  
H.  Handling of Returns (17.8) 
 
Returns should be handled as specified in Section 14.5.  The agents, brokers, traders, distributors, 
repackers, or relabelers should maintain documentation of returned APIs and intermediates. 
(17.80)  
 
 
XVIII. SPECIFIC GUIDANCE FOR APIs MANUFACTURED BY CELL 
CULTURE/FERMENTATION (18) 
 
A.  General (18.1) 
 
Section 18 is intended to address specific controls for APIs or intermediates manufactured by cell 
culture or fermentation using natural or recombinant organisms and that have not been covered 
adequately in the previous sections.  It is not intended to be a stand-alone section.  In general, the 
GMP principles in the other sections of this document apply. Note that the principles of 
fermentation for classical processes for production of small molecules and for processes using 
recombinant and nonrecombinant organisms for production of proteins and/or polypeptides are 
the same, although the degree of control will differ.  Where practical, this section will address 
these differences.  In general, the degree of control for biotechnological processes used to 
produce proteins and polypeptides is greater than that for classical fermentation processes. 
(18.10) 
 
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The term biotechnological process (biotech) refers to the use of cells or organisms that have been 
generated or modified by recombinant DNA, hybridoma, or other technology to produce APIs.  
The APIs produced by biotechnological processes normally consist of high molecular weight 
substances, such as proteins and polypeptides, for which specific guidance is given in this 
Section. Certain APIs of low molecular weight, such as antibiotics, amino acids, vitamins, and 
carbohydrates, can also be produced by recombinant DNA technology. The level of control for 
these types of APIs is similar to that employed for classical fermentation. (18.11) 
 
The term classical fermentation refers to processes that use microorganisms existing in nature 
and/or modified by conventional methods (e.g., irradiation or chemical mutagenesis) to produce 
APIs.  APIs produced by classical fermentation are normally low molecular weight products 
such as antibiotics, amino acids, vitamins, and carbohydrates. (18.12) 
 
Production of APIs or intermediates from cell culture or fermentation involves biological 
processes such as cultivation of cells or extraction and purification of material from living 
organisms.  Note that there may be additional process steps, such as physicochemical 
modification, that are part of the manufacturing process. The raw materials used (media, buffer 
components) may provide the potential for growth of microbiological contaminants.  Depending 
on the source, method of preparation, and the intended use of the API or intermediate, control of 
bioburden, viral contamination, and/or endotoxins during manufacturing and monitoring of the 
process at appropriate stages may be necessary. (18.13) 
 
Appropriate controls should be established at all stages of manufacturing to ensure intermediate 
and/or API quality.  While this guidance starts at the cell culture/fermentation step, prior steps 
(e.g., cell banking) should be performed under appropriate process controls.  This guidance 
covers cell culture/fermentation from the point at which a vial of the cell bank is retrieved for use 
in manufacturing. (18.14) 
 
Appropriate equipment and environmental controls should be used to minimize the risk of 
contamination.  The acceptance criteria for determining environmental quality and the frequency 
of monitoring should depend on the step in production and the production conditions (open, 
closed, or contained systems).  (18.15) 
 
In general, process controls should take into account the following: (18.16) 
 
  Maintenance of the working cell bank (where appropriate) 
  Proper inoculation and expansion of the culture 
  Control of the critical operating parameters during fermentation/cell culture 
  Monitoring of the process for cell growth, viability (for most cell culture processes) and 
productivity, where appropriate 
  Harvest and purification procedures that remove cells, cellular debris and media 
components while protecting the intermediate or API from contamination (particularly of 
a microbiological nature) and from loss of quality 
  Monitoring of bioburden and, where needed, endotoxin levels at appropriate stages of 
production 
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  Viral safety concerns as described in ICH guidance Q5A Quality of Biotechnological 
Products: Viral Safety Evaluation of Biotechnology Products Derived from Cell Lines of 
Human or Animal Origin 
 
Where appropriate, the removal of media components, host cell proteins, other process-related 
impurities, product-related impurities and contaminants should be demonstrated. (18.17) 
 
B.  Cell Bank Maintenance and Record Keeping (18.2) 
 
Access to cell banks should be limited to authorized personnel.  (18.20) 
 
Cell banks should be maintained under storage conditions designed to maintain viability and 
prevent contamination.  (18.21) 
 
Records of the use of the vials from the cell banks and storage conditions should be maintained.  
(18.22) 
 
Where appropriate, cell banks should be periodically monitored to determine suitability for use.  
(18.23) 
 
See ICH guidance Q5D Quality of Biotechnological Products:  Derivation and Characterization 
of Cell Substrates Used for Production of Biotechnological/Biological Products for a more 
complete discussion of cell banking.  (18.24) 
 
C.  Cell Culture/Fermentation (18.3) 
 
Where cell substrates, media, buffers, and gases are to be added under aseptic conditions, closed 
or contained systems should be used where possible.  If the inoculation of the initial vessel or 
subsequent transfers or additions (media, buffers) are performed in open vessels, there should be 
controls and procedures in place to minimize the risk of contamination. (18.30) 
 
Where the quality of the API can be affected by microbial contamination, manipulations using 
open vessels should be performed in a biosafety cabinet or similarly controlled environment. 
(18.31) 
 
Personnel should be appropriately gowned and take special precautions handling the cultures. 
(18.32) 
 
Critical operating parameters (for example temperature, pH, agitation rates, addition of gases, 
pressure) should be monitored to ensure consistency with the established process. Cell growth, 
viability (for most cell culture processes), and, where appropriate, productivity should also be 
monitored.  Critical parameters will vary from one process to another, and for classical 
fermentation, certain parameters (cell viability, for example) may not need to be monitored. 
(18.33) 
  
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Cell culture equipment should be cleaned and sterilized after use.  As appropriate, fermentation 
equipment should be cleaned, sanitized, or sterilized. (18.34) 
 
Culture media should be sterilized before use, when necessary, to protect the quality of the API. 
(18.35) 
 
Appropriate procedures should be in place to detect contamination and determine the course of 
action to be taken.  Procedures should be available to determine the impact of the contamination 
on the product and to decontaminate the equipment and return it to a condition to be used in 
subsequent batches.  Foreign organisms observed during fermentation processes should be 
identified, as appropriate, and the effect of their presence on product quality should be assessed, 
if necessary.  The results of such assessments should be taken into consideration in the 
disposition of the material produced.  (18.36) 
 
Records of contamination events should be maintained. (18.37) 
 
Shared (multi-product) equipment may warrant additional testing after cleaning between product 
campaigns, as appropriate, to minimize the risk of cross-contamination. (18.38) 
 
D.  Harvesting, Isolation and Purification (18.4) 
 
Harvesting steps, either to remove cells or cellular components or to collect cellular components 
after disruption should be performed in equipment and areas designed to minimize the risk of 
contamination. (18.40) 
 
Harvest and purification procedures that remove or inactivate the producing organism, cellular 
debris and media components (while minimizing degradation, contamination, and loss of quality) 
should be adequate to ensure that the intermediate or API is recovered with consistent quality. 
(18.41) 
 
All equipment should be properly cleaned and, as appropriate, sanitized after use.  Multiple 
successive batching without cleaning can be used if intermediate or API quality is not 
compromised. (18.42) 
 
If open systems are used, purification should be performed under environmental conditions 
appropriate for the preservation of product quality. (18.43) 
 
Additional controls, such as the use of dedicated chromatography resins or additional testing, 
may be appropriate if equipment is to be used for multiple products. (18.44) 
 
E.  Viral Removal/Inactivation steps (18.5) 
 
See ICH guidance Q5A Quality of Biotechnological Products: Viral Safety Evaluation of 
Biotechnology Products Derived from Cell Lines of Human or Animal Origin for more specific 
information. (18.50) 
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Viral removal and viral inactivation steps are critical processing steps for some processes and 
should be performed within their validated parameters. (18.51) 
 
Appropriate precautions should be taken to prevent potential viral contamination from previral to 
postviral removal/inactivation steps.  Therefore, open processing should be performed in areas 
that are separate from other processing activities and have separate air handling units. (18.52) 
 
The same equipment is not normally used for different purification steps.  However, if the same 
equipment is to be used, the equipment should be appropriately cleaned and sanitized before 
reuse.  Appropriate precautions should be taken to prevent potential virus carry-over (e.g., 
through equipment or environment) from previous steps.  (18.53) 
 
 
XIX.  APIs FOR USE IN CLINICAL TRIALS (19) 
 
A.  General (19.1) 
 
Not all the controls in the previous sections of this guidance are appropriate for the manufacture 
of a new API for investigational use during its development. Section XIX (19) provides specific 
guidance unique to these circumstances.  (19.10) 
 
The controls used in the manufacture of APIs for use in clinical trials should be consistent with 
the stage of development of the drug product incorporating the API.  Process and test procedures 
should be flexible to provide for changes as knowledge of the process increases and clinical 
testing of a drug product progresses from pre-clinical stages through clinical stages.  Once drug 
development reaches the stage where the API is produced for use in drug products intended for 
clinical trials, manufacturers should ensure that APIs are manufactured in suitable facilities using 
appropriate production and control procedures to ensure the quality of the API.  (19.11) 
 
B.  Quality (19.2) 
 
Appropriate GMP concepts should be applied in the production of APIs for use in clinical trials 
with a suitable mechanism for approval of each batch. (19.20) 
 
A quality unit(s) independent from production should be established for the approval or rejection 
of each batch of API for use in clinical trials. (19.21) 
 
Some of the testing functions commonly performed by the quality unit(s) can be performed 
within other organizational units. (19.22) 
 
Quality measures should include a system for testing of raw materials, packaging materials, 
intermediates, and APIs. (19.23) 
 
Process and quality problems should be evaluated. (19.24) 
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Labeling for APIs intended for use in clinical trials should be appropriately controlled and should 
identify the material as being for investigational use. (19.25) 
 
C.  Equipment and Facilities (19.3) 
 
During all phases of clinical development, including the use of small-scale facilities or 
laboratories to manufacture batches of APIs for use in clinical trials, procedures should be in 
place to ensure that equipment is calibrated, clean, and suitable for its intended use. (19.30) 
 
Procedures for the use of facilities should ensure that materials are handled in a manner that 
minimizes the risk of contamination and cross-contamination. (19.31) 
 
D.  Control of Raw Materials (19.4) 
 
Raw materials used in production of APIs for use in clinical trials should be evaluated by testing, 
or received with a suppliers analysis and subjected to identity testing.  When a material is 
considered hazardous, a supplier's analysis should suffice. (19.40) 
 
In some instances, the suitability of a raw material can be determined before use based on 
acceptability in small-scale reactions (i.e., use testing) rather than on analytical testing alone. 
(19.41) 
 
E.  Production (19.5) 
 
The production of APIs for use in clinical trials should be documented in laboratory notebooks, 
batch records, or by other appropriate means.  These documents should include information on 
the use of production materials, equipment, processing, and scientific observations. (19.50) 
 
Expected yields can be more variable and less defined than the expected yields used in 
commercial processes.  Investigations into yield variations are not expected. (19.51) 
 
F.  Validation (19.6) 
 
Process validation for the production of APIs for use in clinical trials is normally inappropriate, 
where a single API batch is produced or where process changes during API development make 
batch replication difficult or inexact.  The combination of controls, calibration, and, where 
appropriate, equipment qualification ensures API quality during this development phase. (19.60) 
 
Process validation should be conducted in accordance with Section 12 when batches are 
produced for commercial use, even when such batches are produced on a pilot or small scale. 
(19.61) 
 
G.  Changes (19.7) 
 
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Changes are expected during development, as knowledge is gained and the production is scaled 
up.  Every change in the production, specifications, or test procedures should be adequately 
recorded. (19.70) 
 
H.  Laboratory Controls (19.8) 
 
While analytical methods performed to evaluate a batch of API for clinical trials may not yet be 
validated, they should be scientifically sound. (19.80) 
 
A system for retaining reserve samples of all batches should be in place.  This system should 
ensure that a sufficient quantity of each reserve sample is retained for an appropriate length of 
time after approval, termination, or discontinuation of an application. (19.81) 
 
Expiry and retest dating as defined in Section 11.6 applies to existing APIs used in clinical trials.  
For new APIs, Section 11.6 does not normally apply in early stages of clinical trials. (19.82) 
 
I.  Documentation (19.9) 
 
A system should be in place to ensure that information gained during the development and the 
manufacture of APIs for use in clinical trials is documented and available. (19.90) 
 
The development and implementation of the analytical methods used to support the release of a 
batch of API for use in clinical trials should be appropriately documented. (19.91) 
 
A system for retaining production and control records and documents should be used. This 
system should ensure that records and documents are retained for an appropriate length of time 
after the approval, termination, or discontinuation of an application. (19.92) 
 
 
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GLOSSARY (20) 
 
Acceptance Criteria:  Numerical limits, ranges, or other suitable measures for acceptance of test 
results. 
 
Active Pharmaceutical Ingredient (API) (or Drug Substance):  Any substance or mixture of 
substances intended to be used in the manufacture of a drug (medicinal) product and that, when 
used in the production of a drug, becomes an active ingredient of the drug product.  Such 
substances are intended to furnish pharmacological activity or other direct effect in the diagnosis, 
cure, mitigation, treatment, or prevention of disease or to affect the structure and function of the 
body. 
 
API Starting Material:  A raw material, intermediate, or an API that is used in the production of 
an API and that is incorporated as a significant structural fragment into the structure of the API.  
An API starting material can be an article of commerce, a material purchased from one or more 
suppliers under contract or commercial agreement, or produced in-house.  API starting materials 
are normally of defined chemical properties and structure. 
 
Batch (or Lot):  A specific quantity of material produced in a process or series of processes so 
that it is expected to be homogeneous within specified limits.  In the case of continuous 
production, a batch may correspond to a defined fraction of the production.  The batch size can 
be defined either by a fixed quantity or by the amount produced in a fixed time interval. 
 
Batch Number (or Lot Number):  A unique combination of numbers, letters, and/or symbols 
that identifies a batch (or lot) and from which the production and distribution history can be 
determined. 
 
Bioburden:  The level and type (e.g., objectionable or not) of microorganisms that can be 
present in raw materials, API starting materials, intermediates or APIs.  Bioburden should not be 
considered contamination unless the levels have been exceeded or defined objectionable 
organisms have been detected. 
 
Calibration:  The demonstration that a particular instrument or device produces results within 
specified limits by comparison with results produced by a reference or traceable standard over an 
appropriate range of measurements. 
 
Computer System:  A group of hardware components and associated software designed and 
assembled to perform a specific function or group of functions. 
 
Computerized System:  A process or operation integrated with a computer system.  
 
Contamination:  The undesired introduction of impurities of a chemical or microbiological 
nature, or of foreign matter, into or onto a raw material, intermediate, or API during production, 
sampling, packaging, or repackaging, storage or transport. 
 
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Contract Manufacturer:  A manufacturer who performs some aspect of manufacturing on 
behalf of the original manufacturer.  
 
Critical:  Describes a process step, process condition, test requirement, or other relevant 
parameter or item that must be controlled within predetermined criteria to ensure that the API 
meets its specification. 
 
Cross-Contamination:  Contamination of a material or product with another material or 
product. 
 
Deviation:  Departure from an approved instruction or established standard. 
 
Drug (Medicinal) Product:  The dosage form in the final immediate packaging intended for 
marketing. (Reference Q1A) 
 
Drug Substance:  See Active Pharmaceutical Ingredient.  
 
Expiry Date  (or Expiration Date):  The date placed on the container/labels of an API 
designating the time during which the API is expected to remain within established shelf life 
specifications if stored under defined conditions and after which it should not be used. 
 
Impurity:  Any component present in the intermediate or API that is not the desired entity.  
 
Impurity Profile:  A description of the identified and unidentified impurities present in an API.  
 
In-Process Control (or Process Control):  Checks performed during production to monitor and, 
if appropriate, to adjust the process and/or to ensure that the intermediate or API conforms to its 
specifications.  
 
Intermediate:  A material produced during steps of the processing of an API that undergoes 
further molecular change or purification before it becomes an API.  Intermediates may or may 
not be isolated.  (Note: this guidance only addresses those intermediates produced after the point 
that a company has defined as the point at which the production of the API begins.) 
 
Lot:  See Batch 
 
Lot Number:  See Batch Number   
 
Manufacture:  All operations of receipt of materials, production, packaging, repackaging, 
labeling, relabeling, quality control, release, storage, and distribution of APIs and related 
controls. 
 
Material:  A general term used to denote raw materials (starting materials, reagents, solvents), 
process aids, intermediates, APIs, and packaging and labeling materials. 
 
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Mother Liquor:  The residual liquid that remains after the crystallization or isolation processes. 
A mother liquor may contain unreacted materials, intermediates, levels of the API, and/or 
impurities.  It can be used for further processing. 
 
Packaging Material:  Any material intended to protect an intermediate or API during storage 
and transport. 
 
Procedure:  A documented description of the operations to be performed, the precautions to be 
taken, and measures to be applied directly or indirectly related to the manufacture of an 
intermediate or API. 
 
Process Aids:  Materials, excluding solvents, used as an aid in the manufacture of an 
intermediate or API that do not themselves participate in a chemical or biological reaction (e.g., 
filter aid, activated carbon).  
 
Process Control:  See In-Process Control. 
 
Production:  All operations involved in the preparation of an API from receipt of materials 
through processing and packaging of the API. 
 
Qualification:  Action of proving and documenting that equipment or ancillary systems are 
properly installed, work correctly, and actually lead to the expected results.  Qualification is part 
of validation, but the individual qualification steps alone do not constitute process validation.  
 
Quality Assurance (QA):  The sum total of the organized arrangements made with the object of 
ensuring that all APIs are of the quality required for their intended use and that quality systems 
are maintained. 
 
Quality Control (QC):  Checking or testing that specifications are met. 
 
Quality Unit(s):  An organizational unit independent of production that fulfills both quality 
assurance and quality control responsibilities.  This can be in the form of separate QA and QC 
units or a single individual or group, depending upon the size and structure of the organization. 
 
Quarantine:  The status of materials isolated physically or by other effective means pending a 
decision on their subsequent approval or rejection. 
 
Raw Material:  A general term used to denote starting materials, reagents, and solvents intended 
for use in the production of intermediates or APIs. 
 
Reference Standard, Primary:  A substance that has been shown by an extensive set of 
analytical tests to be authentic material that should be of high purity.  This standard can be: (1) 
obtained from an officially recognized source, (2) prepared by independent synthesis, (3) 
obtained from existing production material of high purity, or (4) prepared by further purification 
of existing production material. 
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Reference Standard, Secondary:  A substance of established quality and purity, as shown by 
comparison to a primary reference standard, used as a reference standard for routine laboratory 
analysis. 
 
Reprocessing:  Introducing an intermediate or API, including one that does not conform to 
standards or specifications, back into the process and repeating a crystallization step or other 
appropriate chemical or physical manipulation steps (e.g., distillation, filtration, chromatography, 
milling) that are part of the established manufacturing process.  Continuation of a process step 
after an in-process control test has shown that the step is incomplete, is considered to be part of 
the normal process, and is not reprocessing.  
 
Retest Date:  The date when a material should be re-examined to ensure that it is still suitable 
for use.  
 
Reworking:  Subjecting an intermediate or API that does not conform to standards or 
specifications to one or more processing steps that are different from the established 
manufacturing process to obtain acceptable quality intermediate or API (e.g., recrystallizing with 
a different solvent). 
 
Signature (signed):  See definition for signed. 
 
Signed (signature):  The record of the individual who performed a particular action or review.  
This record can be initials, full handwritten signature, personal seal, or authenticated and secure 
electronic signature.  
 
Solvent:  An inorganic or organic liquid used as a vehicle for the preparation of solutions or 
suspensions in the manufacture of an intermediate or API. 
 
Specification:  A list of tests, references to analytical procedures, and appropriate acceptance 
criteria that are numerical limits, ranges, or other criteria for the test described.  It establishes the 
set of criteria to which a material should conform to be considered acceptable for its intended 
use.  Conformance to specification means that the material, when tested according to the listed 
analytical procedures, will meet the listed acceptance criteria.    
 
Validation:  A documented program that provides a high degree of assurance that a specific 
process, method, or system will consistently produce a result meeting predetermined acceptance 
criteria. 
 
Validation Protocol:  A written plan stating how validation will be conducted and defining 
acceptance criteria.  For example, the protocol for a manufacturing process identifies processing 
equipment, critical process parameters and/or operating ranges, product characteristics, sampling, 
test data to be collected, number of validation runs, and acceptable test results. 
 
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Yield,  Expected:  The quantity of material or the percentage of theoretical yield anticipated at 
any appropriate phase of production based on previous laboratory, pilot scale, or manufacturing 
data. 
 
Yield, Theoretical:  The quantity that would be produced at any appropriate phase of production 
based upon the quantity of material to be used, in the absence of any loss or error in actual 
production. 
 
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