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|S. Sathya Sekhar|
As a part of international regulatory standards of GMP, pharmaceutical industries are required to maintain documentation of the entire manufacturing process and batch execution process.
Pharmaceutical companies have been traditionally using paper to maintain Batch Records (BR) like Batch Manufacturing Records (BMR), BPR, process and equipment templates etc. in order to comply with the requirements of regulatory standards like FDA, MHRA, etc. In this current process, the Batch Records documentation is a manual process, with scores of papers to fill and this is tedious, time-consuming, laborious, monotonous and highly error-prone. A large number of documents are generated and there is a high stipulated retention time for such documents which is posing a great challenge to the industry to manage a highly secured space for storing the documents. A paper-based forms process like Batch Records can be plagued with inefficiency and issues such as wrong issuance, incomplete information, errors and reworks. A study reveals that Batch Record issuance has huge manual and tedious component of work, often turns out to be source of errors and reworks.
For these manual Batch Records, the information has to be collected correctly and completely. With paper forms, the onus lies with the QA team for error- free templates and on the operator to input accurate and complete information. Though manually collected information helps pharma companies meet regulatory requirements, it is very labour-intensive to collect, review and retrieve the information quickly for compliance and production decision making purposes.
In today’s knowledge -based world, information is the greatest asset and quick use of information for improvement is the key to business success. Manual systems don’t connect forms-based processes like audit findings, corrective action, etc. making continuous improvement almost impossible. It is also nearly impossible to analyse and correlate significant volumes of information necessary to improve production processes. Globally, the pharma industry has the need for timely and accurate manufacturing information that can be collected, stored, retrieved, analysed and reported more readily. The only option for efficiently managing these Batch Records is to automate the process.
Challenges faced in manual Batch Record management system
21CFR Part 11 guidelines and automation of Batch Records With the advent of 21 CFR Part 11, the FDA has begun to accept electronic Batch Records. Since then, more and more manufacturers have recognized the advantages of automating the process of controlling Electronic Batch Records (EBR).
Under cGMP regulations found in 21 CFR Parts 210 and 211, the Electronic Batch Record (EBR) must demonstrate the accomplishment of every significant step in the production, packing, and holding of each batch of a drug product. cGMP requires extensive Batch Record documentation, including batch dates, identity of major equipment/lines used, components / materials used and their weights, in-process and laboratory control results, complete labelling control records, sampling, and identification of personnel supervising or checking each step.
In addition to what cGMP requires, manufacturers that automate their Batch Records must do so in accordance with 21 CFR Part 11 requirements.
Benefits of automation of Batch Records:
For the above reasons, pharma manufacturers can migrate from their current manual / paper-based procedures for capturing the BR towards an automated compliance system to cost effectively achieve and maintain compliance with regulatory mandates and prove compliance to internal and external auditors. The end result is sustainable risk reduction, cost reduction, and regulatory compliance. An automated approach for an EBR will reduce the time and effort required by operators to complete manual paperwork, eliminate paperwork error and reduce the time required by supervisors and production investigators to follow-up with responsible person(s) to obtain resolution to anomalies. EBR can save more than 40 per cent of time in preparation, review and approval process, can reduce errors by more than 95% and save costs.
There are software solutions like CaliberBRM available to e-manage your Batch Records in the most efficient and effective manner. CaliberBRM is a very valuable information technology tool for organizing, automating and controlling of BRs in an industry like pharmaceuticals, where Batch Manufacturing takes place and meticulous records are to be maintained, under strict compliance to regulations. It provides an innovative automation solution right from systematic and structured organization of documents to fully automated on-line product documentation.
It organizes repositories for master templates, master BRs, issued BRs, executed BRs, and compiles batch summaries. The master templates, headers, footers, indexes etc are reusable. The document repositories and the workflows are configurable. Execution of BMR may be on-line or off-line. The records can also have scanned signatures to authenticate, along with electronic signatures. CaliberBRM is a complete platform for Batch Records automation and control, with Good Documentation Practice.
It is a DSS for batch yield and quality parameters. It can be integrated with ERP / SAP – for Batch Information, with equipment / SOP Masters – for template preparation, with CAPA / DMS – for Management of Deviations in Quality / Yield Parameters, and with Process Analytics – to capture Batch Analytics.
Implementing Batch Record Management softwares like CaliberBRM in pharma labs would result in big savings in voluminous paperwork, time and effort, and reworks due to human errors. What’s more, this would contribute to the environment too!
(The writer is a Director of Caliber Technologies Private Ltd)