Quality Assurance Unit IV Complaints.
- 1. z Unit – IV Complaints Pharmaceutical Quality Assurance BY: ROHINI A. KAKADE Roll no.31
- 2. z Complaints 1. 2. 3. 4. 5. Points to be covered : Complaints Evaluation of complaints Returned goods Recalling Waste disposal
- 3. z 1.Complaints Defination “Complaint is defined as statement that is something wrong or not good enough, which shows customer dissatisfaction about the company and the product.” Need for complaint handling system It gives the company and opportunity to improve the quality of the product. It is helpful to maintain cGMP. It maintains committee relationship between the customer and company. It is the regulatory obligation.
- 4. z 2.Evaluation of complaints Regulatory literature provides following guidelines: Standard operating procedure should be available giving full details about how to handle products complaints and necessary records about complaints handled should be maintained. A person should be designated for handling the complaints along with sufficient supporting staff to assist him for taking requite descisions. The person should normally be from the quality management department, with sufficient knowledge and experience in related work. If a product defect is suspected in a batch, other batches should also be checked in the order to determine whether they are also affected. All decisions and measures taken as a result of a complaint should be recorded and reference to the corresponding batch records.
- 5. z 1. 2. 3. 4. 5. 6. Return record shall include the following information : Name and strength of the drug product. Lot/ control / batch number. Name of the complainant. Nature of complaint. Reply to complainant. If investigation is made, its complete report. Complaint records shall be regularly reviewed for any indication of specific recurring problems requiring attention and possibly the recall of the marketed product. Trend analysis should be performed in an event to identify possible recurrent causes leading to a negative effect on a product.
- 6. z 3.Returned Goods 1. 2. 3. 4. Pharmaceutical products can be returned from market for various reasons e.g. Quality problems, accidental damage of goods etc. Such products when returned from market should immediately undergo scrutiny as follows: Physical examination of condition of the returned goods and verification of all the relevant documents. Ask Q.C. department to evaluate the quality of the goods received and take a decision on whether these products can be reprocessed, recovered or needs to be destroyed. Q.C. department should evaluate all aspects of the received material. Where even a slightest doubt arises about the quality of the product, it should not be considered suitable for reissue or reuse.
- 7. z 3.1 Classification of returned goods Return goods received by the company at any of its warehouse may be classified in relation to the primary cause of necessitating their cause: Data expired products Damage / broken primary containers Leaky / broken seals of closures of primary containers Smudged labels rendering the products unidentifiable as to their names / batch number Products recalled voluntarily by the company Products recalled as per directives from drug control authorities
- 8. z 3.2 Handling of returned goods: (SOP) Purpose: To lay down systematic procedure to establish handling of returned material / products from market. Scope: This method is applicable for the handling of returned material / products from market. Responsibility: Production head / technical director / head quality assurance. Accountability : Head Quality Assurance.
- 9. z Procedure : Any any material or goods returned from the market shall be stored in a separate area dedicated for storage of returned of goods. Record all the details in returned Goods Record, as per the product record format Inform the Quality Assurance department for evaluation of returned goods. The Quality Assurance chemist shall evaluate the returned goods for the following: a. Check the certificate of analysis and other documents with the returned consignment. b. Condition of the packaging, carton and container.
- 10. z c. Labelling details If the return of material has exceeded the labelled expiry period or the condition of the packaging, carton comma container and storage condition of the material before returning / shipping are doubtful, and then destroy the material as per the SOP for control sample destruction. If none of the above condition is apparent, then sample the material as per the SOP for sampling of the finisher of good. Analyse the sample as per the current approval product specification. In case the sample fills to make the product specification destroy the material / product as per the SOP for destruction and initiate failure investigation. Identify the batches manufactured during the same period or manufactured by using the same raw material and extend the investigation to these batches also.
- 11. z Format for Product Recall Name Batch No. Manuf acturin g date Expiry date Quanti ty Reaso n of return Conditi on Decisi on Date Check ed by Return product details
- 12. z 4. Recalling Defination of Recall : “Recall” means a firm’s removal or correction of a marketed product that the Food and Drug Administration considers to be in violation of the laws it administers and against which the agency would initiate legal action. Objectives Of Recall Stop the distribution and sale of the affected product. Effectively notify Management, customers and regulatory authority. Efficiently remove the affected product from the marketplace, warehouse or distribution areas. Dispose and conduct a root cause analysis and report the effectiveness and outcome of the recall. Implement and corrective action plan to prevent another recall.
- 13. z Recall classification FDA classified the product recall depending on the health hazard caused by the product. Class I is a situation in which there is a responsible probablity that the use of a violative product will cause serious adverse health consequences or death. Class II is a situation in which use of, or exposure to, the violative product may cause temporary or medically reversible adverse health consequences. Class III is a situation in which use of, or exposure to, a violative product is not likely to cause adverse health consequence.
- 14. z 1. 2. 3. 4. 5. 6. Recall procedure Any employee becoming aware of such medicine or any adverse event related to it should immediately notified to higher authorities. Immediately quarantine existing in-house of relevant medicine record the following information: The product name, strength, packs size, batch no., Mfg. and expiry date. Total number of units released for sale. Date on which distribution commenced. Total number of units distributed. Number of units still in stock. Nature of reported violation.
- 15. z In the light of above information higher officials evaluate the health hazard presented by the violation medicine and documents it on “medicine recall control document”. Formulating a proposed recall strategy. It specifies the nature of communication to be used as well as the level in the distribution chain to which recall is extended. Relevant records shall be submitted to regulatory authorities with proposed plan of action. The GM QA / QC regulatory or GM manufacturing implements recall without delay. They also prepare and interim reconciliation report after 30 days and submit a copy to concerned authorities.
- 16. z • • Product information: 1.Manufacturer:_________________________________________________________ 2.Product name:________________________________________________________ 3.Strength:_____________________________________________________________ 4.Pack size:____________________________________________________________ 5.Batch number:________________________________________________________ 6.Total number of units originally released for sale:_____________________________ 7.Date of which distribution commenced:_____________________________________ 8.Total number of units distributed: 9.Number of units still in stock: At factory:____________________________________________________________ With stockist (s):_______________________________________________________ 10.The nature of the reported violation:________________________________________ Medicine recall control document • After that final reconciliation a report of final reconciliation after 90 days is prepared and copy submitted is for verification and steps should be taken to prevent the re occurrence.
- 17. z 1. 2. 3. 4. Prior to completion of recall the following point should be considered: method of destruction of the product. A designed area to receive returned medicines. Inventory of medicine. Destruction authorisation. The recall will be terminated when the GM, QA / QC regulatory or GM manufacturing are assured that recalls has been completed reasonably and a “medicine record status report” is completed. GM, QA / QC regulatory or GM manufacturing shall prepare a “Standardized recall letter” and “press statement”.
- 18. z Date:________ product:__________ strength:______________ Pack size:__________ B.no.:_______ Exp. Date:____________ Nature of defect:______________________________________ Reason for recall:______________________________________ Indication of health risk or any other reason:__________________ Reported clinical problems:________________________________ Method of communication to users: Medicine record status report Method Action Date Target group Number Phone Letter Telegram
- 19. z Dear customer: It has come to our notice (product name)___________ having batch number_____________ or has shown______________ please refrain from prescribing or dispensing any of this batch number and return all you stock of this batch number to our office at:___________________________________ All returned stock or this batch number will be replaced as free of charge. We apologize for any inconvenience caused to you and thank you for your cooperation. Yours faithfully, G.M. QA / QC regulatory. Standardised recall letter and press statement • After the authorisation by GM QA / QC regulatory or GM manufacturing, the recalled material along with stock in hand shall be destroyed and that should be recorded.
- 20. z 5. Waste disposal There should be a written authorised a procedure for handling, destruction and disposal of all rejects, wastage generated during production / handling of pharmaceutical products and printed packaging products. All rejects / wastes should be collected in suitable closed container, labelled appropriately and held in segregated space until taken for destruction. Destruction must be carried out by authorised persons under the supervision of responsible person. Quantities rejected and destroyed must be recorded and reconciled in relevant batch document. Final disposal of residual solid / liquids should be consistent with regulatory requirements including environmental impact.
- 21. z Thank you..!