EN Official Journal of the European Union C 95/1

Guidelines

of 19 March 2015

on principles of Good Distribution Practice of active substances for medicinal products for human use

(Text with EEA relevance)

(2015/C 95/01)

Introduction

These guidelines are based on the fourth paragraph of Article 47 of Directive 2001/83/EC (1).

They follow the same principles that underlie the guidelines of EudraLex Volume 4, Part II, Chapter 17, with regard to the distribution of active substances and the Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2).

These guidelines provide stand-alone guidance on Good Distribution Practice (GDP) for importers and distributors of active substances for medicinal products for human use. They complement the rules on distribution set out in the guidelines of EudraLex Volume 4, Part II, and apply also to distributors of active substances manufactured by themselves.

Any manufacturing activities in relation to active substances, including re-packaging, re-labelling or dividing up, are subject to Commission Delegated Regulation (EU) No 1252/2014 (3) and EudraLex Volume 4, Part II.

Additional requirements apply to the importation of active substances, as laid down in Article 46b of Directive 2001/83/EC.

Distributors of active substances for medicinal products for human use should follow these guidelines as of 21 September 2015.

CHAPTER 1 — SCOPE

1.1. These guidelines apply to distribution of active substances, as defined in Article 1(3a) of Directive 2001/83/EC, for medicinal products for human use. According to that provision, an active substance is any substance or mixture of substances intended to be used in the manufacture of a medicinal product and that, when used in its production, becomes an active ingredient of that product intended to exert a pharmacological, immunological or metabolic action with a view to restoring, correcting or modifying physiological functions or to make a medical diagnosis.

1.2. For the purpose of these guidelines, distribution of active substances shall comprise all activities consisting of procuring, importing, holding, supplying or exporting active substances, apart from brokering.

1.3. These guidelines do not apply to intermediates of active substances.

CHAPTER 2 — QUALITY SYSTEM

2.1. Distributors of active substances should develop and maintain a quality system setting out responsibilities, processes and risk management principles. Examples of the processes and applications of quality risk management can be found in EudraLex Volume 4, Part III: GMP related documents, ICH guideline Q9 on Quality Risk Management (ICH Q9).

2.2. The quality system should be adequately resourced with competent personnel, and suitable and sufficient premises, equipment and facilities. It should ensure that: (i) active substances are procured, imported, held, supplied or exported in a way that is compliant with the requirements of GDP for active substances; (ii) management responsibilities are clearly specified; (iii) active substances are delivered to the right recipients within a satisfactory time period; (iv) records are made contemporaneously; (v) deviations from established procedures are documented and investigated; (vi) appropriate corrective and preventive actions, commonly known as ‘CAPA’, are taken to correct deviations and prevent them in line with the principles of quality risk management; (vii) changes that may affect the storage and distribution of active substances are evaluated.

2.3. The size, structure and complexity of the distributor’s activities should be taken into consideration when developing or modifying the quality system.

CHAPTER 3 — PERSONNEL

3.1. The distributor should designate a person at each location where distribution activities are performed who should have defined authority and responsibility for ensuring that a quality system is implemented and maintained. The designated person should fulfil his responsibilities personally. The designated person can delegate duties but not responsibilities.

3.2. The responsibilities of all personnel involved in the distribution of active substances should be specified in writing. The personnel should be trained on the requirements of GDP for active substances. They should have the appropriate competence and experience to ensure that active substances are properly handled, stored and distributed.

3.3. Personnel should receive initial and continuing training relevant to their role, based on written procedures and in accordance with a written training programme.

3.4. A record of all training should be kept, and the effectiveness of training should be periodically assessed and documented.

CHAPTER 4 — DOCUMENTATION

4.1. Documentation comprises all written procedures, instructions, contracts, records and data, in paper or in electronic form. Documentation should be readily available or retrievable. All documentation related to compliance of the distributor with these guidelines should be made available on request of competent authorities.

4.2. Documentation should be sufficiently comprehensive with respect to the scope of the distributor’s activities and in a language understood by personnel. It should be written in clear, unambiguous language and be free from errors.

4.3. Any alteration made in the documentation should be signed and dated; the alteration should permit the reading of the original information. Where appropriate, the reason for the alteration should be recorded.

4.4. Each employee should have ready access to all necessary documentation for the tasks executed.

Procedures

4.5. Written procedures should describe the distribution activities which affect the quality of the active substances. This could include receipt and checking of deliveries, storage, cleaning and maintenance of the premises (including pest control), recording of the storage conditions, security of stocks on site and of consignments in transit, withdrawal from saleable stock, handling of returned products, recall plans, etc.

4.6. Procedures should be approved, signed and dated by the person responsible for the quality system.

4.7. Attention should be paid to the use of valid and approved procedures. Documents should be reviewed regularly and kept up to date. Version control should be applied to procedures. After revision of a document a system should exist to prevent inadvertent use of the superseded version. Superseded or obsolete procedures should be removed from workstations and archived.

Records

4.8. Records should be clear, be made at the time each operation is performed and in such a way that all significant activities or events are traceable. Records should be retained for at least 1 year after the expiry date of the active substance batch to which they relate. For active substances with retest dates, records should be retained for at least 3 years after the batch is completely distributed.

4.9. Records should be kept of each purchase and sale, showing the date of purchase or supply, name of the active substance, batch number and quantity received or supplied, and name and address of the supplier and of the original manufacturer, if not the same, or of the shipping agent and/or the consignee. Records should ensure the traceability of the origin and destination of products, so that all the suppliers of, or those supplied with, an active substance can be identified. Records that should be retained and be available include: (i) identity of supplier, original manufacturer, shipping agent and/or consignee; (ii) address of supplier, original manufacturer, shipping agent and/or consignee; (iii) purchase orders; (iv) bills of lading, transportation and distribution records; (v) receipt documents; (vi) name or designation of active substance; (vii) manufacturer’s batch number; (viii) certificates of analysis, including those of the original manufacturer; (ix) retest or expiry date.

CHAPTER 5 — PREMISES AND EQUIPMENT

5.1. Premises and equipment should be suitable and adequate to ensure proper storage, protection from contamination, e.g. narcotics, highly sensitising materials, materials of high pharmacological activity or toxicity, and distribution of active substances. They should be suitably secure to prevent unauthorised access. Monitoring devices that are necessary to guarantee the quality attributes of the active substance should be calibrated according to an approved schedule against certified traceable standards.

CHAPTER 6 — OPERATIONS

Orders

6.1. Where active substances are procured from a manufacturer, importer or distributor established in the EU, that manufacturer, importer or distributor should be registered according to Article 52a of Directive 2001/83/EC.

Receipt

6.2. Areas for receiving active substances should protect deliveries from prevailing weather conditions during unloading. The reception area should be separate from the storage area. Deliveries should be examined at receipt in order to check that: (i) containers are not damaged; (ii) all security seals are present with no sign of tampering; (iii) correct labelling, including correlation between the name used by the supplier and the in-house name, if these are different; (iv) necessary information, such as a certificate of analysis, is available; and (v) the active substance and the consignment correspond to the order.

6.3. Active substances with broken seals, damaged packaging, or suspected of possible contamination should be quarantined either physically or using an equivalent electronic system and the cause of the issue investigated.

6.4. Active substances subject to specific storage measures, e.g. narcotics and products requiring a specific storage temperature or humidity, should be immediately identified and stored in accordance with written instructions and with relevant legislative provisions.

6.5. Where the distributor suspects that an active substance procured or imported by him is falsified, he should segregate it either physically or using an equivalent electronic system and inform the national competent authority of the country in which he is registered.

6.6. Rejected materials should be identified and controlled and quarantined to prevent their unauthorised use in manufacturing and their further distribution. Records of destruction activities should be readily available.

Storage

6.7. Active substances should be stored under the conditions specified by the manufacturer, e.g. controlled temperature and humidity when necessary, and in such a manner to prevent contamination and/or mix up. The storage conditions should be monitored and records maintained. The records should be reviewed regularly by the person responsible for the quality system.

6.8. When specific storage conditions are required, the storage area should be qualified and operated within the specified limits.

6.9. The storage facilities should be clean and free from litter, dust and pests. Adequate precautions should be taken against spillage or breakage, attack by micro-organisms and cross-contamination.

6.10. There should be a system to ensure stock rotation, e.g. ‘first expiry (retest date), first out’, with regular and frequent checks that the system is operating correctly. Electronic warehouse management systems should be validated.

6.11. Active substances beyond their expiry date should be separated, either physically or using an equivalent electronic system, from approved stock and not be supplied.

6.12. Where storage or transportation of active substances is contracted out, the distributor should ensure that the contract acceptor knows and follows the appropriate storage and transport conditions. There must be a written contract between the contract giver and contract acceptor, which clearly establishes the duties of each party. The contract acceptor should not subcontract any of the work entrusted to him under the contract without the contract giver’s written authorisation.

Deliveries to customers

6.13. Supplies within the EU should be made only by distributors of active substances registered according to Article 52a of Directive 2001/83/EC to other distributors, manufacturers or to dispensing pharmacies.

6.14. Active substances should be transported in accordance with the conditions specified by the manufacturer and in a manner that does not adversely affect their quality. Product, batch and container identity should be maintained at all times. All original container labels should remain readable.

6.15. A system should be in place by which the distribution of each batch of active substance can be readily identified to permit its recall.

Transfer of information

6.16. Any information or event that the distributor becomes aware of, which have the potential to cause an interruption to supply, should be notified to relevant customers.

6.17. Distributors should transfer all product quality or regulatory information received from an active substance manufacturer to the customer and from the customer to the active substance manufacturer.

6.18. The distributor who supplies the active substance to the customer should provide the name and address of the original active substance manufacturer and the batch number(s) supplied. A copy of the original certificate of analysis from the manufacturer should be provided to the customer.

6.19. The distributor should also provide the identity of the original active substance manufacturer to competent authorities upon request. The original manufacturer can respond to the competent authority directly or through its authorised agents. (In this context ‘authorised’ refers to authorised by the manufacturer.)

6.20. The specific guidance for certificates of analysis is detailed in Section 11.4 of Part II of Eudralex Volume 4.

CHAPTER 7 — RETURNS, COMPLAINTS AND RECALLS

Returns

7.1. Returned active substances should be identified as such and quarantined pending investigation.

7.2. Active substances which have left the care of the distributor, should only be returned to approved stock if all of the following conditions are met: (i) the active substance is in the original unopened container(s) with all original security seals present and is in good condition; (ii) it is demonstrated that the active substance has been stored and handled under proper conditions. Written information provided by the customer should be available for this purpose; (iii) the remaining shelf life period is acceptable; (iv) the active substance has been examined and assessed by a person trained and authorised to do so; (v) no loss of information/traceability has occurred. This assessment should take into account the nature of the active substance, any special storage conditions it requires, and the time elapsed since it was supplied. As necessary and if there is any doubt about the quality of the returned active substance, advice should be sought from the manufacturer.

7.3. Records of returned active substances should be maintained. For each return, documentation should include: (i) name and address of the consignee returning the active substances; (ii) name or designation of active substance, active substance batch number and quantity returned; (iii) reason for return; (iv) use or disposal of the returned active substance and records of the assessment performed.

7.4. Only appropriately trained and authorised personnel should release active substances for return to stock. Active substances returned to saleable stock should be placed such that the stock rotation system operates effectively.

Complaints and recalls

7.5. All complaints, whether received orally or in writing, should be recorded and investigated according to a written procedure. In the event of a complaint about the quality of an active substance the distributor should review the complaint with the original active substance manufacturer in order to determine whether any further action, either with other customers who may have received this active substance or with the competent authority, or both, should be initiated. The investigation into the cause for the complaint should be conducted and documented by the appropriate party.

7.6. Complaint records should include: (i) name and address of complainant; (ii) name, title, where appropriate, and phone number of person submitting the complaint; (iii) complaint nature, including name and batch number of the active substance; (iv) date the complaint is received; (v) action initially taken, including dates and identity of person taking the action; (vi) any follow-up action taken; (vii) response provided to the originator of complaint, including date response sent; (viii) final decision on active substance batch.

7.7. Records of complaints should be retained in order to evaluate trends, product related frequencies, and severity with a view to taking additional, and if appropriate, immediate corrective action. These should be made available during inspections by competent authorities.

7.8. Where a complaint is referred to the original active substance manufacturer, the record maintained by the distributor should include any response received from the original active substance manufacturer, including date and information provided.

7.9. In the event of a serious or potentially life-threatening situation, local, national, and/or international authorities should be informed and their advice sought.

7.10. There should be a written procedure that defines the circumstances under which a recall of an active substance should be considered.

7.11. 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. The designated person (cf. Section 3.1) should be involved in recalls.

CHAPTER 8 — SELF-INSPECTIONS

8.1. The distributor should conduct and record self-inspections in order to monitor the implementation of and compliance with these guidelines. Regular self-inspections should be performed in accordance with an approved schedule.

(1) Directive 2001/83/EC of the European Parliament and of the Council of 6 November 2001 on the Community code relating to medicinal products for human use (OJ L 311, 28.11.2001, p. 67).

(2) OJ C 343, 23.11.2013, p. 1.

(3) Commission Delegated Regulation (EU) No 1252/2014 of 28 May 2014 supplementing Directive 2001/83/EC of the European Parliament and of the Council with regard to principles and guidelines of good manufacturing practice for active substances for medicinal products for human use (OJ L 337, 25.11.2014, p. 1).