GMP Compliance Consulting

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Biological and ATMP manufacturing


“The holder of a manufacturing authorization must manufacture medicinal products so as to ensure that they are fit for their intended use, comply with the requirements of the marketing authorization (MA) and do not place patients at risk due to inadequate safety, quality or efficacy”. (Quote EurdraLex Vol 4)

Manufacturer of medicines for human or veterinary use, are subject to regulatory GMP requirements with regulatory authorities such as the U.S. Food & Drug Administration (FDA) or European Medicines Agency (EMA). They are legally obliged to comply with GMP.

Compliance with Good Manufacturing Practice (GMP) states that medicinal products must be manufactured under specified quality standards to ensure the product’s safety, efficacy and quality. Compliance with GMP is mandatory for all medicinal products to receive the manufacturing authorization and applies over the product life cycle

GMP is a major quality control strategy with emphasis on the process quality. Quality alone cannot be sufficiently tested to the product.

Pharmaceutical products are subject to high quality standards as part of submission for regulatory approval. Among these are: reporting adverse drug reactions; monitoring clinical trials and conducting inspections of manufacturers; compliance with good clinical practice (GCP); good manufacturing practice (GMP); good distribution practice (GDP), and good pharmacovigilance practice (GVP).

For their manufacture, distribution and marketing authorization, a manufacturing license is required. Therefore, for a drug manufacturer, the manufacturing authorization is an essential GMP property. Qualification and validation are key GMP requirements for the implementation of those quality standards. Validation operations, especially in producing sterile biopharmaceuticals, can be very challenging.

The procedures are arduous and requires conscientiousness and commitment, knowledge and experience, as there are predetermined specifications and regulations to meet.

GMP Regulations

FDA statutory and regulatory GMP requirements

Federal Food, Drug, and Cosmetic Act (FDC Act)

The regulatory basis for Good Manufacturing Practice (GMP) is the Federal Food, Drug, and Cosmetic Act (FDC Act). The GMP requirements are codified by the FDA of the Code of Federal Regulations (CFR) Title 21 Food and Drugs parts 210 and 211:

CFR Titel 21 Part 210 – Current good manufacturing practice in manufacturing, processing, packing, or holding of drugs; general

CFR Title 21 Part 211 – Current good manufacturing practice for finished pharmaceuticals


GMP Compliance for Biologicals and Medicinal Products


About Stolley Engineering

Currently biopharmaceuticals are being developed to fight against cancer, autoimmune disorders, infectious diseases and several other medical conditions. Biopharmaceuticals are (mostly) proteins, mainly derived from living systems such as microorganism, animal cell, or plant cell by using recombinant DNA technology.

Proteins can be 100 to 1000 times larger than chemically synthetized small molecules. Due to their large size and complex structure, biopharmaceutical production entails complex manufacturing processes. They are highly sensitive to modification during and after production.

The manufacturing process can affect many parameters, including amino-acid structure, side chains, post-translational processing and tertiary and quaternary structure. Changes could have a profound effect on protein function.

Therefore, biopharmaceuticals are different from synthetic small molecules in terms of molecular size, three-dimensional shape, and process specific impurities. The formulation of the final product is distinct in terms of excipients, bioactivity and stability.

Inconsistencies during manufacturing can lead to inter-batch variations and inconsistency of efficacy. Regarding the manufacture of biopharmaceuticals, the control of quality, safety and efficacy especially in terms of “batch-to-batch” consistency is more complex and demanding.

The responsibility of the regulatory authorities, as part of their review, is to inspect the manufacturing process and the manufacturer’s control strategy for these product variations.


Product Regulation


Bioassay
  • Microbial agents
  • Tumorgenicity
  • Pyrogenicity
GMP Compliance
  • Identity
  • Purity
  • Impurities
  • Potency
  • Quantity
Analytical Method
  • Process Control
  • Validation Program
  • Qualification Program
  • Quality Control Tracking
  • Quality Assurance Tracking


Biological products subject to the PHS Act are licensed under the section 351 of the PHS Act. The regulatory requirement for the BLA is defined in Code of Federal Regulations CFR Title 21 Part 601 Licensing.

The requirements are that the product, the manufacturing process, and the manufacturing facilities meet applicable quality standards to ensure the continued safety, purity and potency of the product.

A potency assay is required due to the complexity and heterogeneity of biotechnological-derived medicinal products.

ATMPs