Guidance for Industry 
Quality Systems Approach to 
Pharmaceutical CGMP Regulations
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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) 
Center for Veterinary Medicine (CVM) 
Office of Regulatory Affairs (ORA) 
 
September 2006 
Pharmaceutical CGMPs  
 
Guidance for Industry 
Quality Systems Approach to 
Pharmaceutical CGMP Regulations
 
 
Additional copies are available from: 
Office of Training and Communication 
Division of Drug Information, HFD-240 
Center for Drug Evaluation and Research 
Food and Drug Administration 
5600 Fishers Lane 
Rockville, MD  20857 
(Tel) 301-827-4573 
http://www.fda.gov/cder/guidance/index.htm 
 
or 
 
Office of Communication, Training and 
Manufacturers Assistance, HFM-40 
Center for Biologics Evaluation and Research 
Food and Drug Administration 
1401 Rockville Pike, Rockville, MD 20852-1448 
http://www.fda.gov/cber/guidelines.htm. 
(Tel) 800-835-4709 or 301-827-1800 
 
or 
 
Communications Staff, HFV-12 
Center for Veterinary Medicine 
Food and Drug Administration 
7519 Standish Place, Rockville, MD  20855 
(Tel) 301-827-3800 
http://www.fda.gov/cvm/guidance/published.html 
 
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) 
Center for Veterinary Medicine (CVM) 
Office of Regulatory Affairs (ORA) 
 
September 2006 
Pharmaceutical CGMP Regulations 
  Contains Nonbinding Recommendations 
 
 
 
 
TABLE OF CONTENTS 
 
 
I.  INTRODUCTION.............................................................................................................1 
II.  BACKGROUND AND PURPOSE..................................................................................1 
A.  Background....................................................................................................................................1 
B.  Goal of the Guidance.....................................................................................................................2 
C.  Scope of the Guidance...................................................................................................................3 
D.  Organization of this Guidance......................................................................................................4 
III.  CGMPS AND THE CONCEPTS OF MODERN QUALITY SYSTEMS...................4 
A.  Quality.............................................................................................................................................4 
B.  Quality by Design and Product Development.............................................................................4 
C.  Quality Risk Management............................................................................................................5 
D.  CAPA (Corrective and Preventive Action)..................................................................................5 
E.  Change Control..............................................................................................................................5 
F.  The Quality Unit............................................................................................................................5 
G.  Six-system Inspection Model.........................................................................................................6 
IV.  THE QUALITY SYSTEMS MODEL.............................................................................8 
A.  Management Responsibilities.......................................................................................................8 
1. Provide Leadership..........................................................................................................................8 
2.  Structure the Organization..............................................................................................................9 
3. Build Your Quality System to Meet Requirements...........................................................................9 
4.  Establish Policies, Objectives, and Plans.....................................................................................10 
5. Review the System..........................................................................................................................10 
B.  Resources......................................................................................................................................12 
1. General Arrangements...................................................................................................................12 
2. Personnel Development.................................................................................................................13 
3. Facilities and Equipment...............................................................................................................13 
4. Control Outsourced Operations....................................................................................................14 
C.  Manufacturing.............................................................................................................................15 
1. Design, Develop, and Document Product and Processes..............................................................15 
2. Examine Inputs..............................................................................................................................16 
3. Perform and Monitor Operations..................................................................................................17 
4. Address Nonconformities...............................................................................................................19 
D.  Evaluation Activities....................................................................................................................21 
1.  Analyze Data for Trends...............................................................................................................21 
2. Conduct Internal Audits.................................................................................................................21 
3. Quality Risk Management..............................................................................................................22 
4. Corrective Action...........................................................................................................................22 
 
  Contains Nonbinding Recommendations 
 
 
5. Preventive Actions.........................................................................................................................23 
6. Promote Improvement....................................................................................................................23 
V.  CONCLUSION...............................................................................................................24 
USEFUL REFERENCE MATERIALS....................................................................................25 
GLOSSARY.................................................................................................................................27 
  
 
  Contains Nonbinding Recommendations 
 
1
Guidance for Industry
Quality Systems Approach to Pharmaceutical Current Good 
Manufacturing Practice Regulations 
 
 
 
This guidance represents the Food and Drug Administration's (FDA's) current thinking on this topic. It 
does not create or confer any rights for or on any person and does not operate to bind FDA or the public. 
You can use an alternative approach if the approach satisfies the requirements of the applicable statutes 
and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for 
implementing this guidance. If you cannot identify the appropriate FDA staff, call the appropriate number 
listed on the title page of this guidance. 
 
 
 
I.  INTRODUCTION 
 
This guidance is intended to help manufacturers implementing modern quality systems and risk 
management approaches to meet the requirements of the Agency's current good manufacturing 
practice (CGMP) regulations (2l CFR parts 210 and 211).  The guidance describes a 
comprehensive quality systems (QS) model, highlighting the model's consistency with the CGMP 
regulatory requirements for manufacturing human and veterinary drugs, including biological 
drug products.  The guidance also explains how manufacturers implementing such quality 
systems can be in full compliance with parts 210 and 211.  This guidance is not intended to place 
new expectations on manufacturers, nor to replace the CGMP requirements.  Readers are advised 
to always refer to parts 210 and 211 to ensure full compliance with the regulations.  
 
FDA's guidance documents, including this guidance, do not establish legally enforceable 
responsibilities. Instead, guidances describe the Agency's current thinking on a topic and should 
be viewed only as recommendations, unless specific regulatory or statutory requirements are 
cited.  The use of the word should in Agency guidances means that something is suggested or 
recommended, but not required. 
  
 
II.  BACKGROUND AND PURPOSE 
 
A.  Background 
 
In August 2002, the FDA announced the Pharmaceutical CGMPs for the 21st Century Initiative. 
In that announcement, the FDA explained the Agencys intent to integrate quality systems and 
risk management approaches into its existing programs with the goal of encouraging industry to 
adopt modern and innovative manufacturing technologies.  The CGMP initiative was spurred by 
the fact that since 1978, when the last major revision of the CGMP regulations was published, 
                                                 
1 This guidance was developed by the Office of Compliance in the Center for Drug Evaluation and Research 
(CDER) in cooperation with the Center for Biologics Evaluation and Research (CBER), the Center for Veterinary 
Medicine (CVM), and the Office of Regulatory Affairs (ORA). 
  1 Contains Nonbinding Recommendations 
 
there have been many advances in manufacturing science and in our understanding of quality 
systems.  In addition, many pharmaceutical manufacturers are already implementing 
comprehensive, modern quality systems and risk management approaches. This guidance is 
intended to help manufacturers implementing modern quality systems and risk management 
approaches to meet the requirements of the Agency's CGMP regulations. The Agency also saw a 
need to harmonize the CGMPs with other non-U.S. pharmaceutical regulatory systems and with 
FDAs own medical device quality systems regulations.  This guidance supports these goals.  It 
also supports the objectives of the Critical Path Initiative, which intends to make the 
development of innovative medical products more efficient so that safe and effective therapies 
can reach patients sooner.   
 
The CGMPs for the 21st Century Initiative steering committee created a Quality System 
Guidance Development working group (QS working group) to compare the current CGMP 
regulations, which call for some specific quality management elements, to other existing quality 
management systems.  The QS working group mapped the relationship between CGMP 
regulations (parts 210 and 211 and the 1978 Preamble to the CGMP regulations2) and various 
quality system models, such as the Drug Manufacturing Inspections Program (i.e., systems-based 
inspectional program),3 the Environmental Protection Agency's Guidance for Developing 
Quality Systems for Environmental Programs, ISO Quality Standards, other quality publications, 
and experience from regulatory cases.  The QS working group determined that, although the 
CGMP regulations do provide great flexibility, they do not incorporate explicitly all of the 
elements that today constitute most quality management systems. 
 
The CGMP regulations and other quality management systems differ somewhat in organization 
and in certain constituent elements; however, they are very similar and share underlying 
principles.  For example, the CGMP regulations stress quality control.  More recently developed 
quality systems stress quality management, quality assurance, and the use of risk management 
tools, in addition to quality control.  The QS working group decided that it would be very useful 
to examine exactly how the CGMP regulations and the elements of a modern, comprehensive 
quality system fit together in today's manufacturing world.  This guidance is the result of that 
examination. 
 
B.  Goal of the Guidance 
 
This guidance describes a comprehensive quality systems model, which, if implemented, will 
allow manufacturers to support and sustain robust, modern quality systems that are consistent 
with CGMP regulations.  The guidance demonstrates how and where the elements of this 
comprehensive model can fit within the requirements of the CGMP regulations.  The inherent 
flexibility of the CGMP regulations should enable manufacturers to implement a quality system 
in a form that is appropriate for their specific operations. 
 
The overarching philosophy articulated in both the CGMP regulations and in robust modern 
quality systems is: 
 
                                                 
2 See Reference #1. 
 
3 See Reference #2. 
  2 Contains Nonbinding Recommendations 
 
Quality should be built into the product, and 
testing alone cannot be relied on to ensure product quality. 
 
This guidance is intended to serve as a bridge between the 1978 regulations and our current 
understanding of quality systems.  In addition to being part of the FDA's CGMP initiative, this 
guidance is being issued for a number of reasons: 
 
  A quality system addresses the public and private sectors mutual goal of providing a high-
quality drug product to patients and prescribers.  A well-built quality system should reduce 
the number of (or prevent) recalls, returned or salvaged products, and defective products 
entering the marketplace.   
  It is important that the CGMP regulations are harmonized to the extent possible with other widely 
used quality management systems, including ISO 9000, non-U.S. pharmaceutical quality 
management requirements, and FDAs own medical device quality system regulations.  This 
guidance serves as a first step to highlight common elements between the CGMP regulations and 
Quality Management Systems.  With the globalization of pharmaceutical manufacturing and the 
increasing prevalence of drug- and biologic-device combination products, the convergence of 
quality management principles across different regions and among various product types is very 
desirable.  
  The FDA has concluded that modern quality systems, when coupled with manufacturing process 
and product knowledge and the use of effective risk management practices, can handle many 
types of changes to facilities, equipment, and processes without the need for prior approval 
regulatory submissions. Manufacturers with a robust quality system and appropriate process 
knowledge can implement many types of improvements.   In addition, an effective quality system, 
by lowering the risk of manufacturing problems, may result in shorter and fewer FDA 
inspections. 
  A quality system can provide the necessary framework for implementing quality by design4 
(building in quality from the development phase and throughout a products life cycle), continual 
improvement, and risk management in the drug manufacturing process.  A quality system adopted 
by a manufacturer can be tailored to fit the specific environment, taking into account factors such 
as scope of operations, complexity of processes, and appropriate use of finite resources. 
 
C.  Scope of the Guidance 
 
This guidance applies to manufacturers of drug products (finished pharmaceuticals), including 
products regulated by the Center for Biologics Evaluation and Research (CBER), the Center for 
Drug Evaluation and Research (CDER), and the Center for Veterinary Medicine (CVM).  It may 
also be useful to manufacturers of components (including active pharmaceutical ingredients) 
used in the manufacture of these products.  
 
This document is not intended to create new requirements for pharmaceutical manufacturing that 
go beyond those established in the current regulations, nor is the guidance intended to be a guide 
for the conduct of FDA inspections.  Rather, the document explains how implementing 
comprehensive quality systems can help manufacturers achieve compliance with 21 CFR parts 
                                                 
4 See ICH Q8 Pharmaceutical Development. 
  3 Contains Nonbinding Recommendations 
 
210 and 211.  Although the QS working group found that many of the quality system elements 
correlate with specific CGMP requirements, some do not.  The Agency expects compliance with 
CGMP regulations, and FDAs inspection program will remain focused on compliance with 
those regulations.  
 
D.  Organization of this Guidance 
 
To provide a reference familiar to industry, the quality systems model described in section IV of 
this guidance is organized  in its major sections  according to the structure of international 
quality standards.  Major sections of the model include the following:   
 
  Management Responsibilities  
  Resources  
  Manufacturing Operations 
  Evaluation Activities 
 
Under each of these sections the key elements found in modern quality systems are discussed.  
When an element correlates with a CGMP regulatory requirement, that correlation is noted.  In 
some cases, a specific CGMP regulation is discussed in more detail as it relates to a quality 
system element.  At the end of each section, a table is included listing the quality system 
elements of that section and the specific CGMP regulations with which they correlate.  A 
glossary is included at the end of the document.  
 
 
III.  CGMPS AND THE CONCEPTS OF MODERN QUALITY SYSTEMS   
 
Several key concepts are critical for any discussion of modern quality systems.  The following 
concepts are used throughout this guidance as they relate to the manufacture of pharmaceutical 
products.   
 
A.  Quality 
 
Every pharmaceutical product has established identity, strength, purity, and other quality 
characteristics designed to ensure the required levels of safety and effectiveness.  For the 
purposes of this guidance document, the phrase achieving quality means achieving these 
characteristics for a product.  
 
B.  Quality by Design and Product Development 
 
Quality by design means designing and developing a product and associated manufacturing 
processes that will be used during product development to ensure that the product consistently 
attains a predefined quality at the end of the manufacturing process.5  Quality by design, in 
conjunction with a quality system, provides a sound framework for the transfer of product 
knowledge and process understanding from drug development to the commercial manufacturing 
processes and for post-development changes and optimization.  The CGMP regulations, when 
                                                 
5 See ICH-Q8 Pharmaceutical Development.  
  4 Contains Nonbinding Recommendations 
 
viewed in their entirety, incorporate the concept of quality by design.  This guidance describes 
how these elements fit together. 
 
C.  Quality Risk Management  
 
Quality risk management is a valuable component of an effective quality systems framework.6 
Quality risk management can, for example, help guide the setting of specifications and process 
parameters for drug manufacturing, assess and mitigate the risk of changing a process or 
specification, and determine the extent of discrepancy investigations and corrective actions.   
 
D.  CAPA (Corrective and Preventive Action) 
 
CAPA is a well-known CGMP regulatory concept that focuses on investigating, understanding, 
and correcting discrepancies while attempting to prevent their recurrence.  Quality system 
models discuss CAPA as three separate concepts, all of which are used in this guidance. 
 
  Remedial corrections of an identified problem 
  Root cause analysis with corrective action to help understand the cause of the deviation 
and potentially prevent recurrence of a similar problem 
  Preventive action to avert recurrence of a similar potential problem 
 
E.  Change Control 
 
Change control is another well-known CGMP concept that focuses on managing change to 
prevent unintended consequences.  The CGMP regulations provide for change control primarily 
through the assigned responsibilities of the quality control unit.  Certain major manufacturing 
changes (e.g., changes that alter specifications, a critical product attribute or bioavailability) 
require regulatory filings and prior regulatory approval (21 CFR 314.70, 514.8, and 601.12). 
   
Effective change control activities (e.g., quality planning and control of revisions to 
specifications, process parameters, procedures) are key components of any quality system.  In 
this guidance, change is discussed in terms of creating a regulatory environment that encourages 
change towards continual improvement.  This means a manufacturer is empowered to make 
changes subject to the regulations based on the variability of materials used in manufacturing and 
process improvements resulting from knowledge gained during a products lifecycle. 
 
F.  The Quality Unit  
 
Many of the modern quality system concepts described here correlate very closely with the 
CGMP regulations (refer to the charts later in the document).  Current industry practice generally 
divides the responsibilities of the quality control unit (QCU), as defined in the CGMP 
regulations, between quality control (QC) and quality assurance (QA) functions. 
 
  QC usually involves (1) assessing the suitability of incoming components, containers, 
closures, labeling, in-process materials, and the finished products; (2) evaluating the 
                                                 
6 See ICH Q9 Quality Risk Management. 
  5 Contains Nonbinding Recommendations 
 
performance of the manufacturing process to ensure adherence to proper specifications 
and limits; and (3) determining the acceptability of each batch for release.  
  QA primarily involves (1) review and approval of all procedures related to production 
and maintenance, (2) review of associated records, and (3) auditing and 
performing/evaluating trend analyses.  
This guidance uses the term quality unit7 (QU) to reflect modern practice while remaining 
consistent with the CGMP definition in  210.3(b)(15).  The concept of a quality unit is also 
consistent with modern quality systems in ensuring that the various operations associated with all 
systems are appropriately planned, approved, conducted, and monitored.  
 
The CGMP regulations specifically assign the QU the authority to create, monitor, and 
implement a quality system.  Such activities do not substitute for, or preclude, the daily 
responsibility of manufacturing personnel to build quality into the product.  The QU should not 
take on the responsibilities of other units of a manufacturers organization, such as the 
responsibilities handled by manufacturing personnel, engineers, and development scientists.8  
Manufacturing personnel and the QU are both critical in fulfilling the manufacturers 
responsibility to produce quality products. 
 
Other CGMP assigned responsibilities of the QU are consistent with modern quality system 
approaches ( 211.22):  
 
  Ensuring that controls are implemented and completed satisfactorily during 
manufacturing operations   
  Ensuring that developed procedures and specifications are appropriate and followed, 
including those used by a firm under contract to the manufacturer 
  Approving or rejecting incoming materials, in-process materials, and drug products  
  Reviewing production records and investigating any unexplained discrepancies   
 
Under a quality system, it is normally expected that the product and process development units, 
the manufacturing units, and the QU will remain independent.  In very limited circumstances, a 
single individual can perform both production and quality functions.  That person is still 
accountable for implementing all the controls and reviewing the results of manufacture to ensure 
that product quality standards have been met.  Under such circumstances, it is recommended that 
another qualified individual, not involved in the production operation, conduct an additional, 
periodic review of QU activities. 
 
G.  Six-system Inspection Model  
 
The FDA's Drug Manufacturing Inspection Compliance Program, which contains instructions to 
FDA personnel for conducting inspections, is a systems-based approach to inspection and is very 
                                                 
7 Generally, the term quality unit is used in this guidance.  However, quality control unit is used when directly 
quoting parts 210 and 211. 
 
8 See Reference #1, comment 91. 
 
  6 Contains Nonbinding Recommendations 
 
consistent with the robust quality system model presented in this guidance.9  The diagram below 
shows the relationship among the six systems: the quality system and the five manufacturing 
systems.  The quality system provides the foundation for the manufacturing systems that are 
linked and function within it. The quality system model described in this guidance does not 
consider the five manufacturing systems as discrete entities, but instead integrates them into 
appropriate sections of the model. Those familiar with the six-system inspection approach will 
see organizational differences in this guidance; however, the inter-relationship should be readily 
apparent. One of the important themes of the systems based inspection compliance program is 
that you have the ability to assess whether each of the systems is in a state of control.  The 
quality system model presented in this guidance will also serve to help firms achieve this state of 
control. 
                                                 
9 See Reference #2; This inspectional approach is currently in use by CDER and by CBER for blood and blood 
product inspections.  CBER and CVM are developing a similar approach for drug product inspections.  
  7 Contains Nonbinding Recommendations 
 
IV.  THE QUALITY SYSTEMS MODEL 
 
The goal of this section is to describe a model for use in pharmaceutical manufacturing that can 
help manufacturers comply with the CGMP regulations.  It should be noted that implementing an 
effective quality system in a manufacturing organization will require a significant investment of 
time and resources.  However, we believe the long-term benefits of implementing a quality 
system will outweigh the costs.10
 
This section describes a robust quality systems model that, if properly implemented, can provide 
the controls to consistently produce a product of acceptable quality.  Where applicable, the 
relationship between elements of this model and CGMP regulations is noted.  At the end of each 
section, a table shows how the specific CGMP regulations correlate to the elements in the quality 
systems model.  As already explained, many of the quality systems elements correlate closely 
with the CGMP regulations.  It is important to emphasize that this guidance is not recommending 
new regulatory requirements.  The guidance is intended to provide recommendations to 
manufacturers who are implementing, or plan to implement, a quality systems model to help 
them comply with CGMP regulations.  FDA regulatory and inspectional coverage will remain 
focused on the specific CGMP regulations. 
 
The model is described according to four major factors:  
 
  Management Responsibilities  
  Resources  
  Manufacturing Operations 
  Evaluation Activities 
 
In each of the sections that follow, the specific elements of a robust modern quality systems 
model are described.  When elements of the quality systems model correlate with specific CGMP 
regulations, this correlation is noted.   
 
A.  Management Responsibilities  
 
Modern robust quality systems models call for management to play a key role in the design, 
implementation, and management of the quality system.  For example, management is 
responsible for establishing the quality system structure appropriate for the specific organization. 
Management has ultimate responsibility to provide the leadership needed for the successful 
functioning of a quality system.  This section describes management's role in developing, 
implementing, and managing a robust quality system.  There is some overlap with the CGMP 
regulations in this section (see the table at the end of the section). 
 
1.  Provide Leadership   
 
In a robust, modern quality system, senior management should demonstrate commitment to 
developing and maintaining their quality system. Quality system plans should be aligned with a 
manufacturers strategic plans to ensure that the system is part of the manufacturers mission and 
quality strategies. For example, quality systems departments normally have equal standing with 
                                                 
10 See Reference #3. 
  8 Contains Nonbinding Recommendations 
 
other departments within an organization.  Quality systems staff are effectively integrated into 
manufacturing activities and are involved in activities such as nonconformance investigations. 
Senior managers set implementation priorities and develop action plans. All levels of 
management can provide support of the quality system by:  
 
  Actively participating in system design, implementation, and monitoring, including 
system review (see IV.A.5.) 
  Advocating continual improvement of operations of the quality system 
  Committing necessary resources  
 
In a robust quality systems environment, all managers should demonstrate strong and visible 
support for the quality system and ensure its implementation throughout the organization (e.g., 
across multiple sites).   
 
All managers should encourage internal communication on quality issues at all levels in the 
organization. Communication should be ongoing among research and development, regulatory 
affairs, manufacturing, and QU personnel on issues that affect quality, with management 
included whenever appropriate.   
 
2.   Structure the Organization 
 
When designing a robust quality system, management has the responsibility to structure the 
organization and ensure that assigned authorities and responsibilities support the production, 
quality, and management activities needed to produce quality products.  Senior managers have 
the responsibility to ensure that the organizations structure is documented.  
 
All managers have the responsibility to communicate employee roles, responsibilities, and 
authorities within the system and ensure that interactions are defined and understood.  
 
An organization also has the responsibility to give the individual who is appointed to manage the 
quality system the authority to detect problems and implement solutions. Usually, a senior 
manager administers the quality system and can, thus, ensure that the organization receives 
prompt feedback on quality issues.  
 
3.  Build Your Quality System to Meet Requirements  
 
Implementing a robust quality system can help ensure compliance with CGMP regulations 
related to drug safety, identity, strength, quality, and purity.  Under the quality systems model, 
the Agency recommends that senior managers ensure that the quality system that is designed and 
implemented provides clear organizational guidance and facilitates systematic evaluation of 
issues.  For example, according to the model, when documenting the implementation of a quality 
system, the following should be addressed: 
 
  The scope of the quality system, including any outsourcing (see IV.B.4.) 
  The quality standard that will be followed 
  The manufacturers policies to implement the quality systems criteria and the 
supporting objectives (see IV.A.4.) 
  9 Contains Nonbinding Recommendations 
 
  The procedures needed to establish and maintain the quality system   
It is recommended under a modern quality systems approach that a formal process be established 
to change procedures in a controlled manner.  It is also recommended that, when operating under 
a quality system, manufacturers develop and document control procedures to complete, secure, 
protect, and archive records, including data, which provide evidence of operational and quality 
system activities.  This approach is consistent with the CGMP regulations, which require 
manufacturers to establish and follow scientifically sound and appropriate written controls for 
specifications, plans, and procedures that direct operational and quality system activities and to 
ensure that these directives are accurate, appropriately reviewed and approved, and available for 
use (see the CGMPs at  211.22 (c) and (d)). 
 
4.   Establish Policies, Objectives, and Plans 
 
Policies, objectives, and plans under a modern quality system provide the means by which senior 
managers articulate their vision of and commitment to quality to all levels of the organization.  
 
Under a quality system, senior management should incorporate a strong commitment to quality 
into the organizational mission.  Senior managers should develop an organizational quality 
policy that aligns with this mission; commit to meeting requirements and improving the quality 
system; and propose objectives to fulfill the quality policy.  Under a quality system, to make the 
policy relevant, it must be communicated to, and understood by, personnel and contractors (if 
applicable) and revised, as needed.  
 
Managers operating within a quality system should define the quality objectives identified for 
implementing the quality policy.  Senior management should ensure that the quality objectives 
are created at the top level of the organization (and other levels as needed) through a formal 
quality planning process.  Objectives are typically aligned with the manufacturers strategic 
plans.  A quality system seeks to ensure that managers support the objectives with necessary 
resources and have measurable goals that are monitored regularly. 
 
Under a quality systems approach, managers would use quality planning to identify and allocate 
resources and define methods to achieve the quality objectives.  Quality system plans should be 
documented and communicated to personnel to ensure awareness of how their operational 
activities are aligned with strategic and quality goals.  
 
5.  Review the System  
 
System review is a key component in any robust quality system to ensure its continuing 
suitability, adequacy, and effectiveness.  Under a quality system, senior managers should 
conduct reviews of the quality systems performance according to a planned schedule.  Such a 
review typically includes assessments of the process, product, and customer needs (in this 
section, customer is defined as the recipient of the product and the product is the goods or 
services provided).   Under a quality systems approach, a review should consider at least the 
following: 
  
  The appropriateness of the quality policy and objectives 
  The results of audits and other assessments 
  10 Contains Nonbinding Recommendations 
 
  Customer feedback, including complaints 
  The analysis of data trending results 
  The status of actions to prevent a potential problem or a recurrence 
  Any follow-up actions from previous management reviews  
  Any changes in business practices or environment that may affect the quality system 
(such as the volume or type of operations) 
  Product characteristics meeting the customers needs 
 
When developing and implementing new quality systems, reviews should take place more 
frequently than when the system has matured.  Outside of scheduled reviews, the quality system 
should typically be included as a standing agenda item in general management meetings.  In 
addition, a periodic review performed by a qualified source, external to the organization, may 
also be useful in assessing the suitability and effectiveness of the system. 
 
Review outcomes typically include: 
 
  Improvements to the quality system and related quality processes 
  Improvements to manufacturing processes and products 
  Realignment of resources  
 
Under a quality system, the results of a management review would typically be recorded.  
Planned actions should be implemented using effective corrective and preventive action and 
change control procedures. 
 
The following table shows how the CGMP regulations correlate to specific elements in the 
quality systems model for this section.  Manufacturers should always refer to the specific 
regulations to make sure they are in compliance. 
 
 
  11 Contains Nonbinding Recommendations 
 
 
21 CFR CGMP Regulations Related to Management Responsibilities 
Quality SystemElement  Regulatory Citations 
1. Leadership   
2. Structure Establish quality function:  211.22 (a) (see definition  
  210.3(b)(15)) 
Notification:  211.180(f) 
3. Build QS  QU procedures:  211.22(d) 
QU procedures, specifications:  211.22(c), with
reinforcement in:  211.100(a), 211.160(a) 
QU control steps:  211.22(a), with reinforcement in  
211.42(c),  211.84(a), 211.87, 211.101(c)(1), 211.110(c), 
211.115(b), 211.142, 211.165(d), 211.192 
QU quality assurance; review/investigate:  211.22(a), 
211.100(a-b) 211.180(f), 211.192,  211.198(a) 
Record control:  211.180(a-d), 211.180(c), 211.180(d), 
211.180(e), 211.186, 211.192, 211.194, 211.198(b)
4. Establish Policies, Objectives and Plans  Procedures:  211.22(c-d), 211.100(a) 
5. System Review   Record review:  211.100, 211.180(e), 211.192, 
211.198(b)(2) 
 
 
B.  Resources 
 
Appropriate allocation of resources is key to creating a robust quality system and complying with 
the CGMP regulations.  This section discusses the role of resources in developing, implementing, 
and managing a robust quality system that complies with the CGMP regulations.  
 
1.  General Arrangements  
 
Under a robust quality system, sufficient resources should be allocated for quality system and 
operational activities.  Under the model, senior management, or a designee, should be 
responsible for providing adequate resources for the following: 
 
  To supply and maintain the appropriate facilities and equipment to consistently 
manufacture a quality product  
  To acquire and receive materials that are suitable for their intended purpose 
  For processing the materials to produce the finished drug product 
  For laboratory analysis of the finished drug product, including collection, storage, and 
examination of in-process, stability, and reserve samples  
 
  12 Contains Nonbinding Recommendations 
 
2.  Personnel Development  
 
Under a quality system, senior management should support a problem-solving and 
communicative organizational culture.  Managers should encourage communication by creating 
an environment that values employee suggestions and acts on suggestions for improvement.  
Management should also develop cross-functional groups to share ideas to improve procedures 
and processes. 
 
In a quality system, personnel should be qualified to do the operations that are assigned to them 
in accordance with the nature of, and potential risk of, their operational activities.  Under a 
quality system, managers should define appropriate qualifications for each position to help 
ensure that individuals are assigned appropriate responsibilities.  Personnel should also 
understand the effect of their activities on the product and the customer.  Although QU personnel 
should not take on the responsibilities of other units of the organization, these personnel should 
be selected based on their scientific and technical understanding, product knowledge, process 
knowledge and/or risk assessment abilities to appropriately execute certain quality functions (this 
quality systems feature is also found in the CGMP regulations, which identify specific 
qualifications, such as education, training, and experience or any combination thereof (see  
211.25(a) and (b)). 
  
Under a quality system, continued training is critical to ensure that the employees remain 
proficient in their operational functions and in their understanding of CGMP regulations.  
Typical quality systems training should address the policies, processes, procedures, and written 
instructions related to operational activities, the product/service, the quality system, and the 
desired work culture (e.g., team building, communication, change, behavior).  Under a quality 
system (and the CGMP regulations), training should focus on both the employees specific job 
functions and the related CGMP regulatory requirements.  
 
Under a quality system, managers are expected to establish training programs that include the 
following: 
 
  Evaluation of training needs  
  Provision of training to satisfy these needs  
  Evaluation of effectiveness of training  
  Documentation of training and/or re-training 
When operating in a robust quality system environment, it is important that managers verify that 
skills gained from training are implemented in day-to-day performance.  
 
3.  Facilities and Equipment  
 
Under a quality system, the technical experts (e.g., engineers, development scientists), who have 
an understanding of pharmaceutical science, risk factors, and manufacturing processes related to 
the product, are responsible for defining specific facility and equipment requirements.   
 
  13 Contains Nonbinding Recommendations 
 
Under the CGMP regulations, the quality unit ( QU) has the responsibility of reviewing and 
approving all initial design criteria and procedures pertaining to facilities and equipment and any 
subsequent changes ( 211.22(c)).   
 
Under the CGMP regulations, equipment must be qualified, calibrated, cleaned, and maintained 
to prevent contamination and mix-ups ( 211.63, 211.67, 211.68).  Note that the CGMP 
regulations require a higher standard for calibration and maintenance than most non-
pharmaceutical quality system models.  The CGMP regulations place as much emphasis on 
process equipment as on testing equipment ( 211.160, 211.63, 211.67, and 211.68) while most 
quality systems focus only on testing equipment.11
 
4.  Control Outsourced Operations  
 
Outsourcing involves hiring a second party under a contract to perform the operational processes 
that are part of a manufacturers inherent responsibilities.  For example, a manufacturer may hire 
another firm to package and label or perform CGMP regulatory training.  Quality systems call 
for contracts (quality agreements) that clearly describe the materials or service, quality 
specification responsibilities, and communication mechanisms.   
 
Under a quality system, the manufacturer should ensure that a contract firm is qualified before 
signing a contract with that firm.  The contract firms personnel should be adequately trained and 
monitored for performance according to their quality system, and the contract firm's and 
contracting manufacturers quality standards should not conflict.  It is critical in a quality system 
to ensure that the management of the contractor be familiar with the specific requirements of the 
contract.  However, under the CGMP requirements, the manufacturers QU is responsible for 
approving or rejecting products or services provided under a contract ( 211.22(a)). 
 
As the following table illustrates, the CGMP regulations are consistent with the elements of a 
quality system in many areas in this section.  However, manufacturers should always refer to the 
specific regulations to ensure that they are complying with all regulations. 
 
2211  CCFFRR  CCGGMMPP  RReegguullaattiioonnss  RReellaatteedd  ttoo  RReessoouurrcceess  
QQQQuuuuaaaalllliiiittttyyyy    SSSSyyyysssstttteeeemmmm    EEEElllleeeemmmmeeeennnntttt     RRRReeeegggguuuullllaaaattttoooorrrryyyy    CCCCiiiittttaaaattttiiiioooonnnn    
11..  GGeenneerraall  AArrrraannggeemmeennttss       
    
22..  DDeevveelloopp  PPeerrssoonnnneell   QQuuaalliiffiiccaattiioonnss::  221111..2255((aa))  
SSttaaffff  nnuummbbeerr::    221111..2255((cc))  
  
SSttaaffff  ttrraaiinniinngg::    221111..2255((aa--bb))  
    
33.. FFaacciilliittiieess  aanndd EEqquuiippmmeenntt   BBuuiillddiinnggss  aanndd  ffaacciilliittiieess::    221111..2222((bb)),,  221111..2288((cc)),,    
221111..4422     221111..5588,,  221111..117733  
    
EEqquuiippmmeenntt::    221111..6633  221111..7722,,  221111..110055,,  221111..116600((bb))((44)),,  
221111..118822  
        
LLaabb  ffaacciilliittiieess::    221111..2222((bb))  
  
                                                 
11 See Reference # 4. 
  14 Contains Nonbinding Recommendations 
 
4. Control Outsourced Operations  Consultants: 211.34 
Outsourcing:  211.22(a)
 
 
 
C.  Manufacturing  
 
Significant overlap exists between the elements of a quality system and the CGMP regulation 
requirements for manufacturing operations.  It is important to emphasize again that FDAs 
enforcement programs and inspectional coverage remain based on the CGMP regulations. When 
quality system elements in this section do not correlate to the CGMP regulations, the guidance 
makes recommendations to help facilitate compliance with the CGMP regulations.  The language 
in this section has been tailored to the pharmaceutical manufacturing environment.  
 
1.  Design, Develop, and Document Product and Processes   
 
In a modern quality systems manufacturing environment, the significant characteristics of the 
product being manufactured should be defined from design to delivery, and control should be 
exercised over all changes.  In addition, quality and manufacturing processes and procedures  
and changes to them  must be defined, approved, and controlled ( 211.100).  It is important to 
establish responsibility for designing or changing products. Documenting processes, associated 
controls, and changes to these processes will help ensure that sources of variability are identified.  
 
Documentation includes: 
 
  RReessoouurrcceess  aanndd  ffaacciilliittiieess  uusseedd  
  Procedures to carry out the process  
  Identification of the process owner who will maintain and update the process as 
needed 
  Identification and control of important variables 
  Quality control measures, necessary data collection, monitoring, and appropriate 
controls for the product and process 
  Any validation activities, including operating ranges and acceptance criteria 
  Effects on related process, functions, or personnel 
As discussed under section IV.A., above, the model calls for managers to ensure that product 
specifications and process parameters are determined by the appropriate technical experts (e.g., 
engineers, development scientists).  In the pharmaceutical environment, experts would have an 
understanding of pharmaceutical science, equipment, facilities, and process types and of how 
variations in materials and processes can ultimately affect the finished product.  
 
Packaging and labeling controls, critical stages in the pharmaceutical manufacturing process, are 
not specifically addressed in quality systems models.  However, the Agency recommends that 
manufacturers always refer to the packaging and labeling control regulations at  211 Subpart G.  
In addition  and this is consistent with modern quality systems  FDA recommends that, as 
  15 Contains Nonbinding Recommendations 
 
part of the design process, before commercial production, the controls for all processes within 
the packaging and labeling system be planned and documented in written procedures.  The 
procedures should outline quality control activities and the responsible positions.  Specifications 
and controls for the packaging and labeling materials should also be determined before 
commercial production.  Distinct labels with discriminating features for different products, such 
as a product marketed with different strengths, should be included to prevent mislabeling and 
resulting recalls.  
 
2.  Examine Inputs  
 
In a modern quality systems model, the term input includes any material that goes into a final 
product, no matter whether the material is purchased by the manufacturer or produced by the 
manufacturer for the purpose of processing.  Materials can include items such as components 
(e.g., ingredients, process water, and gas), containers, and closures.  A robust quality system will 
ensure that all inputs to the manufacturing process are reliable because quality controls will have 
been established for the receipt, production, storage, and use of all inputs.  
 
The CGMP regulations require either testing or use of a certificate of analysis (COA) plus an 
identity analysis ( 211.84) for the release of materials for manufacturing.  In the preamble to the 
CGMP regulations, these requirements were explicitly interpreted.12  The preamble states that 
reliability can be validated by conducting tests or examinations and comparing the results to the 
suppliers COA.  Sufficient initial tests should be done to establish reliability and to determine a 
schedule for periodic reassessment.  As an essential element of purchasing controls, it is 
recommended that data trends for acceptance and rejection of materials be analyzed for 
information on supplier performance.13    
 
The quality systems approach also calls for periodic auditing of suppliers based on risk 
assessment.  During the audit, a manufacturer can observe the testing or examinations conducted 
by the supplier to help determine the reliability of the suppliers COA.  An audit should also 
include a systematic examination of the suppliers quality system to ensure that reliability is 
maintained.  It is recommended that a combination approach be used (i.e., verify the suppliers' 
COA through analysis and audits of the supplier).  Under a quality systems approach, if full 
analytical testing is not done, the audit should cover the suppliers analysis (i.e., a specific 
identity test is still required under  211.84(d)(2)). 
 
Under a quality systems approach, procedures should be established to verify that materials are 
from qualified sources (for application and licensed products, certain sources are specified in the 
submissions).  Procedures should also be established to encompass the acceptance, use, or the 
rejection and disposition of materials produced by the facility (e.g., purified water).  Systems that 
produce these in-house materials should be designed, maintained, qualified, and validated where 
appropriate to ensure that the materials meet their acceptance criteria.  
 
                                                 
12  See Reference #1, comment 239. 
 
13 The Agency recommends that manufacturers have a measure of the variability of materials that could affect their 
process controls.  For example, certain changes in physical properties may affect the process, which may affect a 
finished products dissolution characteristics. 
  16 Contains Nonbinding Recommendations 
 
In addition, it is recommended that changes to materials (e.g., specification, supplier, or 
materials handling) be implemented through a change control system (certain changes require 
review and approval by the QU ( 211.100(a)).  It is also important to have a system in place to 
respond to changes in materials from suppliers so that necessary adjustments to the process can 
be made and unintended consequences avoided. 
 
3.  Perform and Monitor Operations  
 
An important purpose of implementing a quality systems approach is to enable a manufacturer to 
more efficiently and effectively validate, perform, and monitor operations ( 211.100(a)) and 
ensure that the controls are scientifically sound and appropriate.  The goal of establishing, 
adhering to, measuring, and documenting specifications and process parameters is to objectively 
assess whether an operation is meeting its design and product performance objectives.  In a 
robust quality system, production and process controls should be designed to ensure that the 
finished products have the identity, strength, quality, and purity they purport or are represented 
to possess (see, e.g.,  211.100(a)).     
 
In a modern quality system, a design concept established during product development typically 
matures into a commercial design after process experimentation and progressive modification. 
Risk management can help identify areas of process weakness or higher risk and factors that can 
influence critical quality attributes that should receive increased scrutiny. The FDA recommends 
that scale-up studies be used to help demonstrate that a fundamentally sound design has been 
fully realized.  A sufficiently robust manufacturing process should be in place prior to 
commercial production.  With proper design (see IV.C.1.) and reliable mechanisms to transfer 
process knowledge from development to commercial production, a manufacturer should be able 
to validate the manufacturing process.14  Conformance batches provide initial proof that the 
design of the process produces the intended product quality.  Sufficient testing data will provide 
essential information on performance of the new process, as well as a mechanism for continual 
improvement. Modern equipment with the potential for continual monitoring and control can 
further enhance this knowledge base.  Although initial commercial batches can provide evidence 
to support the validity and consistency of the process,15 the entire product life cycle should be 
addressed by the establishment of continual improvement mechanisms in the quality system.16  
Thus, in accordance with the quality systems approach, process validation is not a one-time 
event, but an activity that continues throughout a products life.  
 
As experience is gained in commercial production, opportunities for process improvements may 
become evident. (CGMP regulations  211.180 require the review and evaluation of records to 
determine the need for any change.  These records contain data and information from production 
that provide insight into the products state of control. Change control systems should provide a 
                                                 
14  See Reference #5. 
 
15 Even with good design and development work, initial conformance batches will provide confidence that future 
batches will meet specifications only if the process is repeated within defined operating parameters, equipment 
tolerances, personnel practices, environmental attributes, and material quality. 
 
16 See Reference #6. 
 
  17 Contains Nonbinding Recommendations 
 
dependable mechanism for prompt implementation of technically sound manufacturing 
improvements.) 
 
Under a quality system, written procedures are followed and deviations from them are justified 
and documented (CGMP requires this; see  211.100(b)) to ensure that the manufacturer can 
trace the history of the product, as appropriate, concerning personnel, materials, equipment, and 
chronology and that processes for product release are complete and recorded. 
 
Both the CGMP regulations ( 211.110) and quality systems models call for the monitoring of 
critical processes that may be responsible for causing variability during production. For example:  
 
  Process steps must be verified by a second person ( 211.188).  Process steps can also be 
performed using a validated computer system. Batch production records  must be 
prepared contemporaneously with each phase of production ( 211.100(b)).  Although 
time limits for production can be established when they are important to the quality of the 
finished product (CGMP addresses this; see  211.111), the manufacturer should have the 
ability to establish production controls using in-process parameters that are based on 
desired process endpoints measured using real time testing or monitoring apparatus (e.g., 
blend until mixed vs. blend for 10 minutes). 
  Procedures must be in place to prevent objectionable microorganisms in finished 
products not required to be sterile and to prevent microbial contamination of finished 
products purported to be sterile. Sterilization processes must be validated for sterile drugs 
( 211.113(b)).17  
Manufacturing processes must consistently meet their parameters, and in-process materials 
must meet acceptance criteria or limits ( 211.110(b) and (c)) so that, ultimately, finished 
pharmaceutical products will meet their acceptance criteria. Under a quality system, selected 
data are used to evaluate the quality of a process or product.  In addition, data collection can 
provide a means to encourage and analyze potential suggestions for improvement. A quality 
systems approach calls for the manufacturer to develop procedures that monitor, measure, 
and analyze the operations (including analytical methods and/or statistical techniques).  
Monitoring of the process is important due to the limitations of testing. Knowledge continues 
to accumulate from development through the entire commercial life of a product. Significant 
unanticipated variables should be detected by a well-managed quality system and 
adjustments implemented. Procedures should be revisited as needed to refine operational 
design based on new knowledge. Process understanding increases with experience and helps 
identify when change will lead to continual improvement. When implementing data 
collection procedures, consider the following: 
 
  Are data collection methods documented?  
  When in the product life cycle will the data be collected?  
  How and to whom will measurement and monitoring activities be assigned?  
  When should analysis and evaluation (e.g. trending) of laboratory data be performed? 
(see IV.D.1) 
                                                 
17 See Reference #7. 
  18 Contains Nonbinding Recommendations 
 
  What records should be collected?  
A modern quality system approach indicates that change control is warranted when data analysis 
or other information reveals an area for improvement.  Changes to an established process must 
be controlled and documented to ensure that desired attributes for the finished product will be 
met ( 211.100(a)).   
 
Change control with regard to pharmaceuticals is addressed in more detail in the CGMP 
regulations.  When developing a process change, it is important to keep the process design and 
scientific knowledge of the product in mind. If major design issues are encountered through 
process experience, a firm may want to revisit the adequacy of the design of the manufacturing 
facility ( 211.42), the design of the manufacturing equipment ( 211.63), the design of the 
production and control procedures ( 211.100), or the design of laboratory controls ( 211.160).  
When implementing a change, its effect should be determined by monitoring and evaluating 
those specific elements that may be affected based on an understanding of the process.  This 
approach allows the steps taken to implement a change and the effects of the change on the 
process to be considered systematically.  Application of risk analysis may facilitate evaluating 
the potential effect of the change. Evaluating the effects of a change can entail additional tests or 
examinations of subsequent batches (e.g., additional in-process testing or additional stability 
studies). The quality system elements identified in this guidance, if implemented and maintained, 
will help a manufacturer manage change and implement continual improvement in 
manufacturing. 
  
Under a quality systems approach, procedures should be in place to ensure the accuracy of test 
results. Test results that are out of specification may be due to testing problems or manufacturing 
problems and should be investigated.   Any invalidation of a test result should be scientifically 
sound and justified. 
 
To maintain quality, the Agency recommends that prior to completion of manufacturing, the 
manufacturer should consider storage and shipment requirements to meet special handling needs 
(in the case of pharmaceuticals, one example might be refrigeration). 
 
Under a quality system, trends should be continually identified and evaluated. One way of 
accomplishing this is the use of statistical process control.  The information from trend analyses 
can be used to continually monitor quality, identify potential variances before they become 
problems, bolster data already collected for the annual review, and facilitate improvement 
throughout the product life cycle.  Process capability assessment can serve as a basis for 
determining the need for changes that can result in process improvements and efficiency (see 
IV.D.1.).   
 
4.  Address Nonconformities 
 
A key component in any quality system is handling nonconformities and/or deviations. The 
investigation, conclusion, and follow-up must be documented ( 211.192).  To ensure that a 
product conforms to requirements and expectations, it is important to measure the process and 
the product attributes (e.g., specified control parameters, strength) as planned.  Discrepancies 
may be detected during any stage of the process or during quality control activities.  Not all 
discrepancies will result in product defects; however, it is important to document and handle 
  19 Contains Nonbinding Recommendations 
 
discrepancies appropriately.  A discrepancy investigation process is critical when a discrepancy 
is found that affects product quality (CGMP also requires this;  
see  211.192). 
 
In a quality system, it is important to develop and document procedures that define who is 
responsible for halting and resuming operations, recording non-conformities, investigating 
discrepancies, and taking remedial action.  Under a quality system, if a product or process does 
not meet requirements, it is essential to identify and/or segregate the product so that it is not 
distributed to the customer.  Remedial action can include any of the following:  
 
  Correct the non-conformity  
  With proper authorization, allow the product to proceed with justification of the 
conclusions regarding the problems impact 
  Use the product for another application where the deficiency does not affect the products 
quality 
  Reject the product  
 
The corrected product or process should also be re-examined for conformance and assessed for 
the significance of the non-conformity (see, e.g.,  211.115).  If the non-conformity is 
significant, based on consequences to process control, process efficiency, product quality, safety, 
efficacy, and product availability, it is important to evaluate how to prevent recurrence (see 
IV.D.4.).  If an individual product that does not meet requirements has been released, the product 
can be recalled.18  Customer complaints must be reviewed and then investigated if a discrepancy 
is identified ( 211.198). 
 
The following table shows how the CGMP regulations correlate to specific elements in the 
quality systems model.  Manufacturers should always refer to the specific regulations to ensure 
that they are complying with all regulations. 
                                                 
18  See 21 CFR Part 7. 
  20 Contains Nonbinding Recommendations 
 
 
 
21 CFR CGMP Regulations Related to Manufacturing Operations 
Quality SystemElement  Regulatory Citation 
1.Design andDevelop Product and Processes  Production:  211.100(a)
2.Examine Inputs  Materials:  210.3(b), 211.80211.94, 211.101, 
211.122,211.125 
3. Perform and Monitor Operations  Production:  211.100, 211.103, 211.110, 211.111, 
211.113 
QC criteria: 211.22(a-c), 211.115(b), 211.160(a), 
211.165(d), 211.188
QC checkpoints:  211.22 (a),211.84(a),211.87, 
211.110(c) 
4.Address Nonconformities  Discrepancy investigation:  211.22(a), 211.100, 
211.115, 211.192,  211.198
Recalls: 21 CFR Part 7
 
 
D.  Evaluation Activities 
 
As in the previous section, the elements of a quality system correlate closely with the 
requirements in the CGMP regulations.  See the table at the end of the section for the specifics. 
 
1.   Analyze Data for Trends  
 
Quality systems call for continually monitoring trends and improving systems.  This can be 
achieved by monitoring data and information, identifying and resolving problems, and 
anticipating and preventing problems. 
 
Quality systems procedures involve collecting data from monitoring, measurement, complaint 
handling, or other activities, and tracking this data over time, as appropriate. Analysis of data can 
provide indications that controls are losing effectiveness. The information generated will be 
essential to achieving problem resolution or problem prevention (see IV.D.3.).  
 
Although the CGMP regulations ( 211.180(e)) require product review on at least an annual 
basis, a quality systems approach calls for trending on a more frequent basis as determined by 
risk.  Trending enables the detection of potential problems as early as possible to plan corrective 
and preventive actions.  Another important concept of modern quality systems is the use of 
trending to examine processes as a whole; this is consistent with the annual review approach. 
Trending analyses can help focus internal audits (see IV.D.2.). 
  
2.  Conduct Internal Audits 
 
A quality systems approach calls for audits to be conducted at planned intervals to evaluate 
effective implementation and maintenance of the quality system and to determine if processes 
and products meet established parameters and specifications.  As with other procedures, audit 
  21 Contains Nonbinding Recommendations 
 
procedures should be developed and documented to ensure that the planned audit schedule takes 
into account the relative risks of the various quality system activities, the results of previous 
audits and corrective actions, and the need to audit the complete system. Procedures should 
describe how auditors are trained in objective evidence gathering, their responsibilities, and 
auditing procedures.  Procedures should also define auditing activities such as the scope and 
methodology of the audit, selection of auditors, and audit conduct (audit plans, opening 
meetings, interviews, closing meeting and reports).  It is critical to maintain records of audit 
findings and assign responsibility for follow-up to prevent problems from recurring (see 
IV.D.3.). 
 
The quality systems model calls for managers who are responsible for the areas audited to take 
timely action to resolve audit findings and ensure that follow-up actions are completed, verified, 
and recorded. (FDAs policy is to refrain from both reviewing and copying reports or records 
that result from internal audits per Compliance Policy Guide 130.300.19) 
 
3.  Quality Risk Management 
  
Effective decision-making in a quality systems environment is based on an informed 
understanding of quality issues. Elements of risk should be considered relative to intended use of 
a product, and in the case of pharmaceuticals, patient safety and ensuring availability of 
medically necessary drug products.  Management should assign priorities to activities or actions 
based on an assessment of the risk including both the probability of occurrence of harm and of 
the severity of that harm.  It is important to engage appropriate parties in assessing the risk.  Such 
parties include customers, appropriate manufacturing personnel, and other stakeholders.  
Implementation of quality risk management includes assessing the risks, selecting and 
implementing risk management controls commensurate with the level of risk, and evaluating the 
results of the risk management efforts.  Since risk management is an iterative process, it should 
be repeated if new information is developed that changes the need for, or nature of, risk 
management.  
 
In a manufacturing quality systems environment, risk management is used as a tool in the 
development of product specifications and critical process parameters.  Used in conjunction with 
process understanding, quality risk management helps manage and control change.  
 
4.  Corrective Action 
 
Corrective action is a reactive tool for system improvement to ensure that significant problems 
do not recur.  Both quality systems and the CGMP regulations emphasize corrective actions. 
Quality systems approaches call for procedures to be developed and documented to ensure that 
the need for action is evaluated relevant to the possible consequences, the root cause of the 
problem is investigated, possible actions are determined, a selected action is taken within a 
defined timeframe, and the effectiveness of the action taken is evaluated. It is essential to 
document corrective actions taken (CGMP also requires this; see  211.192). 
 
It is essential to determine what actions will reduce the likelihood of a problem recurring.  
Examples of sources that can be used to gather such information include the following: 
                                                 
19  See Reference #8. 
  22 Contains Nonbinding Recommendations 
 
 
  Nonconformance reports and rejections  
  Returns 
  Complaints  
  Internal and external audits  
  Data and risk assessment related to operations and quality system processes  
  Management review decisions  
 
5.  Preventive Actions 
 
Being proactive is an essential tool in quality systems management. Succession planning, 
training, capturing institutional knowledge, and planning for personnel, policy, and process 
changes are preventive actions that will help ensure that potential problems and root causes are 
identified, possible consequences assessed, and appropriate actions considered.  
 
The selected preventive action should be evaluated and recorded, and the system should be 
monitored for the effectiveness of the action.  Problems can be anticipated and their occurrence 
prevented by reviewing data and analyzing risks associated with operational and quality system 
processes, and by keeping abreast of changes in scientific developments and regulatory 
requirements. 
 
6.  Promote Improvement 
 
The effectiveness and efficiency of a quality system can be improved through the quality 
activities described in this guidance.  Management may choose to use other improvement 
activities as appropriate.  It is critical that senior management be involved in the evaluation of 
this improvement process (see IV.D.3.).  
 
The following table shows how the CGMP regulations correlate to specific elements in the 
quality systems model for this section.  Manufacturers should always refer to the specific 
regulations to make sure they are complying with all regulations. 
  23 Contains Nonbinding Recommendations 
 
 
21 CFR CGMP Regulations Related to Evaluation Activities 
Quality System Element  Regulatory Citation 
1.Analyze DataforTrends  Annual Review:  211.180(e) 
2. Conduct Internal Audits  -- 
3. RiskAssessment 
4.Corrective Action  Discrepancy investigation:  211.22(a), 211.192
5.Preventive Action  
6. Promote Improvement   211.110 
 
 
V.  CONCLUSION 
 
Implementation of a comprehensive quality systems model for human and veterinary 
pharmaceutical products, including biological products, will facilitate compliance with 21 CFR 
parts 210 and 211.  The central goal of a quality system is the consistent production of safe and 
effective products and ensuring that these activities are sustainable.  Quality professionals are 
aware that good intentions alone will not ensure good products.  A robust quality system will 
promote process consistency by integrating effective knowledge-building mechanisms into daily 
operational decisions.  Specifically, successful quality systems share the following 
characteristics, each of which has been discussed in detail above: 
  
  Science-based approaches  
  Decisions based on an understanding of the intended use of a product  
  Proper identification and control of areas of potential process weakness  
  Responsive deviation and investigation systems that lead to timely remediation  
  Sound methods for assessing and reducing risk  
  Well-defined processes and products, starting from development and extending 
throughout the product life cycle  
  Systems for careful analysis of product quality  
  Supportive management (philosophically and financially)  
 
Both good manufacturing practice and good business practice require a robust quality system. 
When fully developed and effectively managed, a quality system will lead to consistent, 
predictable processes that ensure that pharmaceuticals are safe, effective, and available for the 
consumer. 
 
 
 
 
 
  24 Contains Nonbinding Recommendations 
 
USEFUL REFERENCE MATERIALS 
 
 
1.  1978 Preamble to the Good Manufacturing Practice Final Regulations  Federal Register 
Docket No. 73N-0339] http://www.fda.gov/cder/dmpq/preamble.txt  
2.  CPGM 7356.002 Compliance Program  Drug Manufacturing Inspections 
http://www.fda.gov/cder/dmpq/compliance_guide.htm  
3.  Quality Planning and Analysis, 3rd Ed. by  J.M. Juran, F.M. Gryna (McGraw-Hill, New 
York, N.Y. 1993)     
4.  ANSI/ISO/ASQ Q9000-2000:  Quality management systems  Fundamentals and vocabulary, 
(American Society for Quality, 2000) 
5.  Guideline of General Principles of Process Validation, May 1987  
http://www.fda.gov/cder/guidance/pv.htm  
6.  FDA Compliance Policy Guide 7132c.08 Process Validation Requirements for Drug 
Products and Active Pharmaceutical Ingredients Subject to Pre-Market Approval, updated 
03-12-2004  http://www.fda.gov/ora/compliance_ref/cpg/cpgdrg/cpg490-100.html  
7.  Guidance for Industry - Sterile Drug Products Produced by Aseptic Processing Current 
Good Manufacturing Practice  September 2004. See also the draft guidance on 
investigating Out-of-Specification (OOS) Test Results for Pharmaceutical Production.   
   
8.  FDA Compliance Policy Guide Sec. 130.300, FDA Access to Results of Quality Assurance 
Program Audits and Inspections, (CPG 7151.02)    
http://www.fda.gov/ora/compliance_ref/cpg/cpggenl/cpg130-300.html         
9.  Criteria for Performance Excellence, Business (Baldrige National Quality Program, NIST 
2003) http://baldrige.nist.gov/PDF_files/2003_Business_Criteria.pdf   
10. ANSI/ISO/ASQ Q9001-2000: Quality management systems  Requirements (American 
Society for Quality, 2000) 
11. ANSI/ISO/ASQ Q9004-2000: Quality management systems  Guidelines for performance 
improvement (American Society for Quality, 2000) 
12. ANSI/ISO 17025-1999: General requirements for the competence of testing 
      and calibration laboratories (American Society for Quality, 1999) 
13. CMMI-SE/SW, V1.1: Capability Maturity Model Integration for Systems Engineering and 
Software Engineering, Staged Representation (Software Engineering Institute, Carnegie 
Mellon University, 2002) http://www.sei.cmu.edu/pub/documents/02.reports/pdf/02tr002.pdf  
14. The Balanced Scorecard Institute: http://balancedscorecard.org  
15. Guidance for Developing Quality Systems for Environmental Program (EPA QA/G-1, Nov 
2002) http://www.epa.gov/quality/qs-docs/g1-final.pdf 
16. Guidance for Industry Q7A Good Manufacturing Practice Guidance for Active 
Pharmaceutical Ingredients (U.S. Department of Health and Human Services/ Food and 
Drug Administration, August 2001) . 
  25 Contains Nonbinding Recommendations 
 
17. Good Manufacturing Practices for Pharmaceutical Products: Main Principles (World Health 
Organization Technical Report Series, No. 908, 2003) 
http://www.who.int/medicines/library/qsm/trs908/trs908-4.pdf 
18. Procedures For The Implementation of The Federal Managers Financial Integrity Act 
(FMFIA); (FDA Staff Manual Guide 2350.1) 
19. Managing the Risks from Medical Product Use: Creating a Risk Management Framework 
(U.S. FDA, 1999) http://www.fda.gov/oc/tfrm/1999report.html 
20. Framework for Environmental Health Risk Assessment  Final Report, Vol.1 
(Presidential/Congressional Commission on Risk Assessment and Risk Management, 1997) 
http://www.riskworld.com/Nreports/1997/risk-rpt/pdf/EPAJAN.PDF  
21. Report on FDA Quality System Framework for Pharmaceutical Product Regulation 
Activities; (Quality System Framework Subcommittee, December 2003)  
22. Tutorials for Continuous Quality Improvement (Clemson University, 1995) 
http://deming.eng.clemson.edu/pub/tutorials/   
23. Variation Risk Management  Focusing Quality Improvement in Product Development and 
Products by Anna C. Thornton (John Wiley and Sons, Inc.; Hoboken, New Jersey, 2004 
24. Guidance for Industry for the Submission of Documentation for Sterilization Process 
Validation in Applications for Human and Veterinary Drug Products   
http://www.fda.gov/cder/guidance/cmc2.pdf  
25. Chapter 3, Quality Management in the American Pharmaceutical Industry, in 
Pharmaceutical Quality, Ed. by R. Prince (DHI Publishing, River Grove, IL, 2004) 
 
  26 Contains Nonbinding Recommendations 
 
GLOSSARY 
 
To gain a common understanding of a quality systems approach, the following terms are used 
throughout the guidance.  
 
Annual Review  An evaluation, conducted at least annually, that assesses the quality standards 
of each drug product to determine the need for changes in drug product specifications or 
manufacturing or control procedures 
 
CAPA  Corrective and preventive action: A systematic approach that includes actions needed 
to correct (correction), prevent recurrence (corrective action), and eliminate the cause of 
potential nonconforming product and other quality problems (preventive action) (21CFR 
820.100) 
 
Continual Improvement  Ongoing activities to evaluate and positively change products, 
processes, and the quality system to increase effectiveness  
 
Correction  Repair, rework, or adjustment relating to the disposition of an existing discrepancy 
 
Corrective Action  Action taken to eliminate the causes of an existing discrepancy or other 
undesirable situation to prevent recurrence 
 
Customer  A person or organization (internal or external) that receives a product or service 
anywhere along the products life cycle 
 
Discrepancy  Datum or result outside of the expected range; an unfulfilled requirement; may be 
called non-conformity, defect, deviation, out-of-specification, out-of-limit, out-of-trend 
 
Harm  Damage to health, including the damage that can occur from the loss of product quality 
or availability 
 
Non-conformity  A deficiency in a characteristic, product specification, process parameter,  
record, or procedure that renders the quality of a product unacceptable, indeterminate, or not 
according to specified requirements 
 
Preventive Action   Action taken to eliminate the cause of a potential discrepancy or other 
undesirable situation to prevent such an occurrence  
 
Product/Service  The intended results of activities or processes; products/services can be 
tangible or intangible 
 
Quality  A measure of a products or services ability to satisfy the customers stated or implied 
needs 
 
Quality Assurance  Proactive and retrospective activities that provide confidence that 
requirements are fulfilled 
 
  27 Contains Nonbinding Recommendations 
 
Quality Control  The steps taken during the generation of a product or service to ensure that it 
meets requirements and that the product or service is reproducible  
 
Quality Management  Accountability for the successful implementation of the quality system  
 
Quality Objectives  Specific measurable activities or processes to meet the intentions and 
directions as defined in the quality policy 
 
Quality Plan  The documented result of quality planning that is disseminated to all relevant 
levels of the organization  
 
Quality Planning  A management activity that sets quality objectives and defines the 
operational and/or quality system processes and the resources needed to fulfill the objectives  
 
Quality Policy  A statement of intentions and direction issued by the highest level of the 
organization related to satisfying customer needs.  It is similar to a strategic direction that 
communicates quality expectations that the organization is striving to achieve. 
 
Quality System  Formalized business practices that define management responsibilities for 
organizational structure, processes, procedures, and resources needed to fulfill product/service 
requirements, customer satisfaction, and continual improvement  
 
Quality Unit  A group organized within an organization to promote quality in general practice 
 
Risk  The combination of the probability of occurrence of harm and the severity of that harm 
 
Risk Assessment  A systematic process for organizing information to support a risk decision   
that is made within a risk management process.  The process consists of the identification of 
hazards and the analysis and evaluation of risks associated with exposure to those hazards. 
 
Risk Management  The systematic application of quality management policies, procedures, 
and practices to the tasks of assessing, controlling, communicating, and reviewing risk 
 
Senior Management  Top management officials in a firm who have the authority and 
responsibility to mobilize resources 
 
Stakeholder  An individual or organization having an ownership or interest in the delivery, 
results, and metrics of the quality system framework or business process improvements 
 
Verification  Confirmation, through the provision of objective evidence, that specified 
requirements have been fulfilled. (Reference:  The ASQ Auditing Handbook, 3rd edition, ASQ 
Quality Audit Division, J.P. Russell, Editor) 
 
Validation  Confirmation, through the provision of objective evidence, that the requirements 
for a specific intended use or application have been fulfilled. (Reference:  The ASQ Auditing 
Handbook, 3rd edition, ASQ Quality Audit Division, J.P. Russell, Editor) 
  28