Good Laboratory Practice (GLP): A Comprehensive Overview of the techniques adopted in GLP with respect to Quality Assurance
Khan Adil Ahmed*, Dr. G.J. Khan
J.I.I.U’S Ali-Allana College of Pharmacy
Akkalkuwa, Dist.- Nandurbar (425415) Maharashtra, India.
Abstract:
Good Laboratory Practice (GLP) is a set of internationally recognized
principles that ensure the quality and integrity of non-clinical laboratory
studies conducted for regulatory purposes. This review article provides an
overview of GLP, its history, principles, and current perspectives. The
article also discusses the importance of GLP in the drug development
process, the regulatory frameworks that govern GLP, and the future
directions of GLP.
Keywords:
Academic Health Centers; Software; Laboratory
Management; Guidance; Good Laboratory Practice; Quality Assurance.
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Corresponding Author:
Khan Adil Ahmed
Email ID:
kadil2406@gmail.com
Contact No: 7718989244
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Article History
Received: 22/09/2023
Accepted: 13/10/2023 Published: 01/11/2023
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INTRODUCTION:
Good
Laboratory Practice (GLP) is a quality assurance system that is widely used in
non-clinical laboratory studies conducted for regulatory purposes. The
principles of GLP were first established in the 1970s in response to concerns
about the quality and reliability of laboratory data submitted to regulatory
authorities(2). Today, GLP is a fundamental requirement for non-clinical
laboratory studies conducted for the development of pharmaceuticals, chemicals,
and other products.
1.
"Good Laboratory Practice (GLP) is a quality system concerned with the
organizational process and the conditions under which non-clinical health and
environmental safety studies are planned, performed, monitored, recorded,
archived, and reported" (OECD, 1998).
2.
"Good Laboratory Practice (GLP) is a quality system concerned with the
organizational process and the conditions under which non-clinical health and
environmental safety studies are planned, performed, monitored, recorded,
archived, and reported" (FDA, 2018).
3.
"Good Laboratory Practice (GLP) is a set of principles intended to assure
the quality and integrity of non-clinical laboratory studies that are intended
to support research or marketing permits for products regulated by government
agencies" (ICH, 1997). Everyone makes mistakes, so that's why GLP is
necessary. Even if you are not required to follow the standards, it's always a
good idea to follow GLP principles. Say what you do (with written standard
operating procedures), do what you say (follow the procedures), and be able to
prove it (with good record keeping). The principles of good laboratory practice
(GLP) are intended to aid in the development of high-quality and credible test
data for determining the safety of chemicals and chemical products. Hence, GLP
strives to reduce the possibility of errors or confusions by extensive and
detailed labelling standards. The registered data can be given by proving the
application of the proper item in the specified quantities to the relevant test
systems.
History of GLP:
The FDA
established GLP as an official regulation in 1978. The OECD (Organization for
Economic Co-operation and Development) Principles of Good Laboratory Practice
were developed initially by an Expert Group on GLP established in 1978 under
the Special Programme on Chemical Control.The work of the Expert Group, which
was led by the United States and comprised experts from the following nations
and organizations: Australia, Austria, Belgium, Canada, Denmark, France, the
Federal Republic of Germany, Greece, Italy, Japan, the Netherlands, New
Zealand, Norway, Sweden, Switzerland, provided the foundation for the work of
the GLP regulations that are recognized as international standards for non-clinical
laboratory studies published by the US Food and Drug Administration in 1976.
After the United States, several nations eventually created GLP regulations in
their own jurisdictions(1).
The OECD
Council officially recommended the GLP Principles for use in member countries
in 1981. They were established as an essential component of the Council
Decision on Mutual Acceptance of Data in Chemical Assessment, which states that
"data denoted in the testing of chemicals in an OECD member country in
accordance with OECD Test Guidelines and OECD Principles of Good Laboratory
Practice shall be accepted in other member countries for the purposes of
assessment and other uses relating to the protection of man and the
environment(2).
The OECD's
work on chemical safety is held through the Environmental Health and Safety
Division. The Environmental Health and Safety Division issues available Modern
Approaches to Quality Control 36 documents in six series: Pesticides; Risk
Management; Chemical Accidents; and Harmonization of Regulatory Oversight in
Biotechnology are some of the topics covered in this course. There are many
national guidelines setting Good Laboratory Practice, the one guideline that is
most universally accepted by the various national guidelines is the regulation
of GLP through the Principles of Good Laboratory Practice of the Organization
of Economic Cooperation and Development (OECD), since these have been discussed
by an international panel of experts and have been agreed on at an
international level; they also form the basis for the OECD Council
Decision/Recommendation on the Mutual Acceptance of Data in the Assessment of
Chemicals which has to be regarded as one of the cornerstone agreements amongst
the OECD member states with regard to trade in chemicals and to the removal of
non-tariff barriers to trade. Besides the utilization of the OECD Guidelines
for the Testing of Chemicals, they restated the application of GLP Principles
and the establishment of consorted national GLP compliance monitoring programmes
as necessary parts of the mutual acceptability of data. The working group of
experts who had created the OECD Principles of Good Laboratory Practice also
proceeded to inform and publish guidance for the Monitoring Authorities with
regard to the introduction of procedures essential for the monitoring of
industry's compliance with these Principles, as well as guidance with respect
to the actual conduct of the necessary control activities such as laboratory
inspections and study audits.
Principles of GLP:
Good
Laboratory Practice (GLP) is a set of
guidelines and regulations that are designed to ensure the quality and
integrity of non-clinical laboratory studies. These studies are conducted to
evaluate the safety and efficacy of chemicals, drugs, and other products, as
well as to understand their potential impacts on the environment(4).
The
principles of GLP cover a wide range of topics, including study design,
documentation, data analysis, and quality control. In this essay, I will
discuss these principles in detail and explain why they are essential for
ensuring the reliability and credibility of non-clinical laboratory studies.
1. Study Design
The first principle of GLP is to ensure that non-clinical laboratory
studies are designed and conducted in a manner that allows for accurate and
reliable results. This includes ensuring that the study is well-designed, with
clear objectives, appropriate controls, and sufficient statistical power. The
study design should be described in a written protocol, which should be
reviewed and approved by the study sponsor, as well as the study director and
other relevant personnel.
2. Personnel
The second principle of GLP is to ensure that the personnel
conducting the study are qualified and trained to perform their duties. This
includes having appropriate education, training, and experience in their
respective areas of expertise, as well as receiving ongoing training to ensure
that they stay up to date with the latest procedures and techniques. Personnel
should be well-informed of the study protocol, standard operating procedures
(SOPs), and other relevant documentation, and should adhere to these guidelines
throughout the study.
3. Facilities
The third principle of GLP is to ensure that the facilities in which
the study is conducted are appropriate for the type of study being conducted.
This includes ensuring that the facilities are equipped with appropriate
instruments, equipment, and other resources, and that they are maintained in a
clean, orderly, and secure manner. Facilities should also be designed and
maintained to prevent contamination or cross-contamination of test substances
or test systems.
4. Standard Operating Procedures
The fourth principle of GLP is to ensure that all procedures and
processes used in the study are documented in written SOPs. These SOPs should
provide detailed instructions for all aspects of the study, including sample
handling, analysis, and reporting. SOPs should be reviewed and approved by the
study director, and any deviations from SOPs should be documented and
explained.
5. Documentation
The fifth principle of GLP is to ensure that all study data and
results are accurately documented and reported. This includes maintaining a
comprehensive record of all study procedures, data, and results, as well as any
deviations from the study protocol or SOPs. All study documentation should be
archived and retained for a period of time specified by regulatory authorities.
6. Quality Control
The sixth principle of GLP is to ensure that appropriate quality
control procedures are in place throughout the study. This includes the use of
appropriate controls, regular calibration and maintenance of equipment, and the
validation of test methods. Quality control procedures should be documented and
reviewed regularly to ensure that they are effective and consistent with
regulatory requirements.
7. Data Analysis and Reporting
The seventh principle of GLP is to ensure that all study data are
analyzed and reported in a manner that is clear, accurate, and reliable. This
includes ensuring that statistical analyses are appropriate for the type of
data being analyzed, and that all results are reported in a manner that is
consistent with the study protocol and regulatory requirements. Study reports
should be reviewed and approved by the study director, and any inconsistencies
or discrepancies should be documented and explained (2).
Future Directions of GLP:
The field of Good Laboratory Practice (GLP) is constantly evolving
to keep pace with changes in technology and scientific understanding. Here are
some possible future directions for GLP:
1.
Integration with emerging
technologies: As new technologies such as
artificial intelligence, machine learning, and big data become more prevalent
in laboratory studies, GLP guidelines will need to be updated to ensure that
they are applied appropriately. GLP will need to work closely with other
regulatory bodies to develop guidelines for the use of these technologies in
laboratory studies(3).
2.
Focus on data management and
analysis: With the increasing complexity of
laboratory studies and the massive amount of data generated, GLP will need to
focus more on data management and analysis. This includes developing guidelines
for data storage, sharing, and analysis, as well as ensuring the accuracy and
completeness of data.
3.
Greater emphasis on risk assessment: GLP may place greater emphasis on risk assessment in the future, to
identify potential hazards and risks associated with laboratory studies. This
may include developing guidelines for hazard identification, risk evaluation,
and risk management.
4.
Incorporation of sustainability: As the world becomes more focused on sustainable development, GLP
may incorporate guidelines for sustainable practices in laboratory studies.
This includes guidelines for reducing waste, minimizing environmental impact,
and promoting sustainable practices in laboratory operations.
5.
Development of new standards: As the field of laboratory studies continues to evolve, new
standards and guidelines may need to be developed to ensure that GLP remains
relevant and effective. This may include standards for emerging areas of
research, such as nanotechnology or gene editing.
Independence of QA
The QA personnel should be under the
direct responsibility of the Test Facility Management (TFM) and should not have
any role in the studies they inspect. If QA personnel are involved in other
activities within the facility, such as management of Standard Operating
Procedures or calibration and maintenance, these activities should be inspected
by an independent person appointed by TFM. For small test facilities or those
with infrequent GLP activities, TFM must dedicate at least one person, even
part-time, for coordination of the QA function. It is acceptable for
individuals involved in the conduct of studies to perform the QA function for
GLP studies in other departments as long as there is no link to their own
studies within the test facility and there is a clear reporting line direct to
TFM. The independence of QA personnel should always be ensured and
demonstrated, and independent inspections should not have any hierarchical link
between the auditor and the auditee.
TFM is responsible for appointing
designated personnel for the QAP and allocating appropriate resources to QA. QA
personnel must have access to different levels of management, and their tasks should
not compromise their independence or involve them in the direction and conduct
of studies. Inspection results should be promptly reported to TFM, and a
summary of planned QA activities and achievements should be presented
regularly. TFM is responsible for ensuring appropriate resources for studies
and should not have any QA role.
The study director must ensure effective
communication with QA personnel during the study, and provide them with a copy
of the study plan and any amendments in a timely manner. QA should schedule
inspections based on the up-to-date version of the master schedule, and
identify the critical phases of the study. Active involvement of QA personnel
is necessary at all stages of the study. If deviations from GLP Principles,
study plans or SOPs are detected during inspections, QA personnel should
document observations and communicate them to the study directors. Study
directors must receive inspection reports and respond promptly with
corrections.(5)
1. Training of QA personal:
QA personnel having a thorough
understanding of GLP principles, as well as the relevant test procedures, study
plans, and standards. It is recommended that QA personnel have training in
methods and tools for conducting thorough inspections, as well as communication
and social skills. TFM (Test Facility Management) is responsible for ensuring
that there is a documented training program for QA personnel, which should
include on-the-job experience and attendance at relevant seminars and courses.
The training of QA personnel must be documented and kept up-to-date.
Quality Assurance Program (QAP) in test
facilities to ensure compliance with GLP principles. The QAP should include
inspections by QA personnel, who should maintain SOPs for planning, scheduling,
and documenting inspections. The GLP Principles specify three types of
inspections: study-based inspections, facility-based inspections, and
process-based inspections. Adopting a risk-based approach to the QAP can help
in determining the type, frequency, and scope of inspections to be carried out.
Risk assessment can be used to identify potential issues and impact on GLP
compliance, and a QAP should be designed and implemented accordingly. The text
also emphasizes the need for documentation and evaluation of the risk
assessment process and output.
2. Risk manegment:
TFM has the responsibility of ensuring
that a risk assessment is conducted and approved. The risk assessment process
involves considering various factors such as the risks to GLP compliance,
activities performed in the test facility, problems that may occur during any
activity, the probability of such problems occurring, their detectability, and
the impact on GLP compliance. The history of the test facility can be used to
identify risks by analyzing previous deviations, weaknesses associated with
activities, root cause analyses of events, and corrective and preventive
actions plans. After identifying the risks, TFM should put controls in place to
mitigate and detect them, which can reduce the risk of compromising GLP
compliance and support a reduced frequency or different scope of QA monitoring.
The risk assessment process helps identify the areas of highest residual risk,
which are likely to be subject to the most frequent QA inspections. However,
areas of lower risk still need to be inspected, but the frequency or depth of
inspections may be reduced. Periodic review of the risk-based QAP is expected,
taking into account changes in the test facility such as increased volume of
work, new technologies, changes to key personnel, and new regulations or
guidance documents. For larger test facilities, it may be appropriate to
consider risks on a departmental or specific area basis to allow for
differences in approach at a local operational level.
3. Verification of study plan:
The process of verifying the study plan is
necessary to ensure that it contains all the required information and meets the
GLP Principles. This verification should be defined in a Standard Operating
Procedure (SOP) and the results should be documented in an inspection report or
other relevant documentation. It is recommended that the verification of the
study plan is conducted before the start of the study or at least before the
experimental starting date. Any amendments to the study plan should be verified
in the same manner as the original plan. The study plan can also be used to
plan inspections, identifying the critical experimental phases of the study to
be inspected in cooperation with study directors. QA should retain a copy of
the approved study plan, any amendments, and all relevant SOPs during the
study.
For short-term studies using general study
plans, it may be appropriate to verify the plan periodically based on a
risk-based approach, rather than for each study. In such cases, study-specific
supplements, containing details of the test item, conditions of its
application, identities of the study director and sponsor(s), and the study
calendar, should be issued as a supplementary document requiring only the dated
signature of the designated study director. These study-specific supplements
should also be verified by QA. The general plan and the supplement together
form the unique study plan.
4. Study-based inspections:
The quality of Good Laboratory Practice
(GLP) studies should be overseen by QA personnel through inspections conducted
throughout the duration of the study. The selection and frequency of
inspections should be based on the chronology of the study and the associated
risks. The focus should be on the activities that present the greatest risk for
the compliance of the study, and the identification of such phases should be
made in cooperation with the study director or another scientist/technical
expert who has an in-depth understanding of the methodology used. The level of
QA oversight required may vary from study to study depending on length and
complexity, and emphasis should always be placed on inspecting the activities
associated with the highest risk. If not all the experimental phases are
inspected, the consolidated planning of the inspected phases should be arranged
in a way that all the types of experimental phases are inspected in a defined
period. To develop an effective inspection program, critical phases that are
essential to maintaining the quality, validity, and reliability of the study
should be identified. This includes unusual or new technical procedures,
unusual test items, and overarching procedures used to conduct and manage the
study. QA personnel should have specific knowledge and training relevant to the
critical phases being inspected, and physical presence at the location where
the inspected activity is conducted is essential. Inspections of the
experimental phases should verify that the study plan, its amendments, and
relevant SOPs have been made available to study personnel in the location where
the phase is conducted, and that the instructions in the study plan, its
amendments, and SOPs are followed by the study personnel. Inspections are also
opportunities to check the way raw data are recorded by study personnel and to
inspect the resources used in the experimental phase.
5. Inspection of study report:
The Good Laboratory Practice (GLP)
Principles require that all final study reports claiming GLP compliance should
be inspected by Quality Assurance (QA) personnel. The main objective of this
inspection is to ensure that the study was conducted in accordance with the
study plan, amendments, and Standard Operating Procedures (SOPs) and that any
discrepancies are documented as deviations and communicated to the study
director. Additionally, the report should accurately describe the methods and
procedures used in the study, reflect the raw data, and contain all the
elements required by the GLP Principles and requested in the study plan and
amendments. QA personnel should have access to all the documentation, raw data,
and study materials required for the inspection. It is recommended that the
inspection is carried out when all raw data have been gathered, quality control
checks completed, no more major changes are intended, and the sponsor's
comments, if any, have been addressed by the study director. Any changes made
to the study report after the inspection must be communicated to QA. For
short-term studies, a single general study report may be prepared containing the
majority of generic information required in such a report. The general study
report should be periodically inspected by QA personnel, and any study-specific
supplements should be systematically inspected.
The quality assurance (QA) procedures for
inspecting raw data should be clearly defined in a Standard Operating Procedure
(SOP) to ensure that the raw data is thoroughly examined at different stages of
the study. The inspection process may begin during the experimental phase or
process-based inspections, and the final inspection of the raw data should
occur at the draft report stage, once all quality control checks have been
completed. To verify the quality, integrity, and completeness of the raw data,
several considerations should be taken into account. First, the raw data should
conform to the requirements of the GLP Principles, and the format of the raw
data recording should be retainable. Second, a risk assessment may identify the
minimum percentage or sample size of raw data to be inspected in a study, and
these procedures should include rules for sample selection and instructions in
case errors are detected. Third, any modifications to raw data should be
signed, dated, and justified, with a focus on justifications for changes made
after the original data input. Fourth, the extent of the inspection of raw data
should be based on a risk-based approach and may depend on the nature of the
systems used to capture, generate, analyze, transfer, and store study raw data.
Finally, QA should not correct or modify raw data, nor should any stamps or
marks be used on the raw data or copies of it. It is essential to formalize the
inspection of raw data to ensure that all necessary checks are carried out.
However, QA should avoid using any practices that modify or cover the original
raw data. By adhering to these guidelines, the inspection process of raw data
will be more reliable, and the results of the study will be more accurate.
6. Facility and process-based
inspections:
Facility and process-based inspections are
essential in verifying compliance with Good Laboratory Practice (GLP) and
applicable Standard Operating Procedures (SOPs). These inspections are
conducted independently of specific studies, with the purpose of monitoring
study phases or procedures, or systems relevant to studies. Process-based
inspections are designed to oversee routine activities, minimizing Quality
Assurance (QA) resources while providing oversight for a number of studies. The
types of activities that may be covered by process-based inspections include
test item administration, specimen collection, inoculation of cell lines, and
sample preparation procedures. Decisions on inspection frequency should take
into account the implications for compliance if the process fails and be
assessed on a case-by-case basis. Factors used to establish an appropriate
inspection frequency include the risks associated with the activity, compliance
history, quality control procedures, and criticality of the activity to the
study outcome or test facility's operations. The frequency and complexity of
the activity are important determining factors, as are the number of operators
performing the activity and their experience. One of the key challenges for a
process-based inspection program is ensuring that observations are
representative of actual occurrences. Combining study-specific and
process-based inspection programs is an acceptable practice, allowing QA to
focus resources on high-risk activities associated with a study. Routine
activities that are common to several different types of studies can also be
subject to a process-based inspection that does not distinguish between study
types. In summary, facility and process-based inspections play a crucial role
in ensuring compliance with GLP and SOPs, and their effective implementation
involves taking several factors into account.
Facility-based inspections are essential
in ensuring that test facilities are appropriate for their intended purposes
and are adequately maintained. These inspections encompass the overall
facilities and activities within the test facility, and may include non-study
specific activities such as equipment maintenance and calibration. The scope of
these inspections is broad and includes aspects such as management, personnel
training, study management, equipment adequacy and maintenance, computerized
systems validation and use, test systems management, and archiving. The
frequency, nature, and extent of facility-based inspections may be determined
by a documented risk assessment. For example, low-risk activities may require
fewer and less in-depth inspections, while high-risk activities may necessitate
more frequent and extensive inspections. When assessing risk, it is important
to consider how different GLP areas operate independently within the same test
facility. Risk assessments should also take into account differences in
procedures and levels of criticality among various areas within the facility.
Ultimately, facility-based inspections are critical in ensuring that test
facilities operate in accordance with GLP principles and regulations. Regular
inspections help to identify and mitigate compliance issues, ensuring the
accuracy, reliability, and integrity of study results. By identifying and
addressing potential compliance issues before they become problematic,
facility-based inspections play an important role in upholding the principles
of good laboratory practice.
7. Verification of the management of
the QAP and Required material for the conduct of the inspections:
The verification of the Quality Assurance
Program (QAP) is an essential aspect of ensuring compliance with the Good
Laboratory Practice (GLP) Principles. As with any other GLP activity, the
functioning of the QAP should be subject to verification by the Test Facility
Management (TFM). TFM should have internal processes in place to continuously
monitor the effectiveness of the QAP, including an internal assessment
procedure. Relying solely on external auditing or regulatory inspection results
is not sufficient. Inspections of QA activities, conducted by trained
individuals independent of GLP QA, can be used to verify the QAP periodically.
Both QA personnel and TFM should be able to justify the methods used for the
conduct and oversight of the inspection program. In addition, certain materials
should be readily available upon request to QA personnel for scheduling and
conducting inspections, including an up-to-date version of the master schedule,
study plans, applicable SOPs, generated study materials (such as raw data,
samples, and specimens), and documentation on the study environment and
resources used, personnel and training, and validation records of computerized
systems (including spreadsheets)
8. QA inspection reports and Communication of the inspection report:
The QA inspection report is a crucial
document that summarizes the results of an inspection. It should include
details about the scope of the inspection, standards used, dates, and full
identification of the study. Additionally, it should contain details about the
nature of the inspected areas and/or activities, as well as the results of the
inspection. The findings should be clearly described so that they are
understood by the auditees, and the name(s), signature(s) of the auditor(s),
and the date the report is issued should be included. The report should provide
an accurate record of the inspection performed, and the level of detail should
be sufficient to enable retention of a comprehensive record. Communication of
the report should be prompt, and QA should promptly report study-based
inspection results in writing to TFM and the study director. Facility-based
inspection results should be reported to TFM, and all study directors should be
informed of the outcomes of each facility-based inspection to assess the
potential impact on their studies. Process-based inspection results should also
be reported to TFM and all relevant study directors. In case of detection of
findings that could jeopardize the GLP compliance of the studies or the test
facility, it is highly recommended that such findings are immediately
communicated even before a formal inspection report is issued. The effective
date of transmission to the study director and to TFM of each inspection report
should be recorded and those records retained. Although checklists can be
useful tools, they should not prevent the auditor from adapting the scope of
the inspection.
9. Response to the inspection report:
The process of conducting inspections in
the context of Good Laboratory Practice (GLP) regulations requires that
findings identified during a study or process-based inspection are properly
addressed. In order to ensure this, the study director must take responsibility
for responding to the findings. For facility-based inspections, the Test
Facility Management (TFM) is the most suitable authority to ensure that the
findings are addressed in a timely manner, and a maximum response time may be
defined in the Standard Operating Procedures (SOPs) to ensure timely responses.
In the case of study-related inspections, the study director has a number of
responsibilities. These include ensuring that answers are provided to Quality
Assurance (QA) findings, deciding on corrections to the findings, proposing a
schedule to ensure that study-related findings are corrected within the study
timelines, and assessing the impact of the QA findings on the validity of the
study. Corrective and preventive actions may be proposed in response to an
inspection report to prevent similar findings from reoccurring. If necessary,
TFM should approve the answers proposed by the study director, especially in
cases where the implementation of new resources or modifications in the SOPs is
required. Responses to the inspection reports should be transmitted back to QA
so that they can verify that all the outcomes of the inspection are addressed,
and evaluate the proposed solutions for compliance with GLP Principles. For the
inspection of the final study report, procedures must be established so that QA
is made aware of all additions or changes made to the study data and report
during the inspection phase. QA should ensure that all issues raised in the QA
inspection have been appropriately addressed in the final study report and that
no changes to the study report have been made which would require a
complementary inspection. It is essential that any corrections to findings that
may jeopardize the GLP compliance of the study are implemented before the
issuance of the QA statement in the final study report.
10. SOP for QA
Standard operating procedures (SOPs) for
quality assurance (QA) should clearly outline the different activities that are
part of the quality assurance program (QAP), such as planning, scheduling,
performing, documenting, and reporting inspections. These SOPs should be
approved by the Test Facility Management (TFM). The SOPs can specify different
types of inspections such as study-based, process-based, and facility-based
inspections(5).
The SOPs should include requirements that
every study must be inspected, and minimum parts of each study should be
inspected. Additionally, the scope of inspections should be clearly defined
and, if necessary, an exhaustive list of the scopes should be provided. A
detailed description of the areas to be covered and the depth of verification
for each scope of inspection should also be included in the SOPs. The planning
and scheduling of inspections should include the availability of an up-to-date
master schedule of the studies, criteria for the selection of experimental
phases to be inspected in a study, a definition of a critical phase,
identification of experimental study phases that could be subjected to
process-based inspections, frequencies of periodic inspections, and available
tools to ensure the schedule and follow the realization of the program. The
SOPs should also describe the available tools to assess the workload of QA. The
performance of the inspection should also be described in the SOPs. The different
steps of the inspection, from preparation to issuance of the inspection report,
should be outlined. Depending on the scope of the inspection, the particular
topics to be examined during the inspection can be described in the SOPs. The
documentation and reporting of the outcomes of the inspection should also be
addressed in the SOPs. A maximum time between the end of the inspection and the
issuance of the inspection report may be defined, and a template for an
inspection report can be supplied. The mechanism for transmission of inspection
reports to TFM and the study director, timelines for response, and procedures
for dealing with disagreements between QA and auditees should also be included
in the SOPs. The process for verifying the corrections due to inspection
outcomes and the rules for issuing QA statements to be included in the study
reports should be described in the SOPs. The SOPs should also include the way
of reporting the capability of the QAP to ensure its role in the GLP compliance
of the studies and the test facility, and the means of verification of the QAP
by TFM. The SOPs should also specify the competences, qualifications, and
training required for QA personnel. Additionally, the archiving of QA
documentation, rules or ways of communication between QA and the other GLP
functions, and the management of QA in multi-site studies, as Lead QA and/or
test site QA should be addressed in the SOPs. Overall, the SOPs for QA should
be comprehensive and cover all aspects of the quality assurance program. They
should be approved by TFM and followed by QA personnel to ensure the proper
functioning of the QAP and to maintain GLP compliance in studies and the test
facility.
11. Documentation and record:
The documentation and records of the QAP
activities, including all inspection reports, should be properly stored and
managed by the archivist. This may include verifying study plans and their
amendments, QAP schedules, reporting tools, training files of QA personnel, and
computer system validation files used by QA. Retired or replaced QA SOPs must
also be kept. While QA notes are not considered raw data, they may need to be
retained if the level of detail in the inspection reports or other information
is insufficient to reconstruct QA activities. To maintain confidentiality, the
QA file specific to a study may be archived separately from the study file to
prevent its transfer from the test facility archives to the sponsor at the end
of the retention period. This is particularly important when the test facility
and sponsor do not belong to the same organization. The QA statements are
retained with the study reports, and their contents are critical to the overall
integrity of the study report. The archivist must ensure that all the
documentation related to the QAP activities and inspection outcomes are stored
and managed as required.
CONCLUSION:
The independence of Quality Assurance (QA) is crucial for ensuring the
integrity and reliability of data generated during research studies. A
well-trained QA team can effectively manage risks and verify study plans, as
well as conduct study-based and process-based inspections to ensure that all
activities are performed according to pre-established protocols and standards.
The inspection of study reports and facilities is an essential part of QA, as
it provides a comprehensive view of the entire study process and enables
identification of potential issues that could compromise the study's outcomes.
The verification of the management of the QAP and required materials for the
conduct of inspections ensures that the QA process is adequately resourced and
can be executed efficiently.QA inspection reports and communication of the
inspection report are also crucial components of the QA process, as they enable
effective communication between the QA team, the study sponsor, and regulatory
agencies. Response to the inspection report is equally important, as it
demonstrates the commitment of the study team to addressing any issues
identified during the inspection process.
To ensure consistency and standardization in the QA process, the
development of SOPs for QA is critical. SOPs provide a clear framework for the
execution of QA activities and ensure that all team members are aware of their
roles and responsibilities. Documentation and record-keeping are also essential
to demonstrate compliance with regulatory requirements and enable traceability
of activities. In summary, QA is a critical component of research studies, and
the independence of QA personnel is essential to ensure the integrity and
reliability of data generated during the study. A well-trained QA team can
manage risks, verify study plans, conduct inspections, and provide effective
communication between the study team, sponsor, and regulatory agencies. SOPs,
documentation, and record-keeping are also essential to ensure consistency and
standardization in the QA process.
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