Is it necessary for a manufacturer of medicinal products to comply with the Good Distribution Practices (GDP) or is this the task of the wholesalers and distribution companies?
>> GDP requirements are very similar to the requirements stated in the GMP for manufacturers in relation to storage of medicinal products. Manufacturers must comply with the product storage requirements as stated in the GMP.
Iin addition, if they are responsible for the distribution of their products, they
also need to follow the GDP requirements; these include storage and transportation of their products in line with the product label, ensuring its safety and security throughout the supply chain.
According to Chapter 2, paragraph 2.2. each wholesaler needs to designate a person as Responsible Person for GDP. Are there any circumstances in which the manufacturer of the medicinal product needs to designate a Responsible Person?
>> The EU Manufacturing authorization includes the wholesaler’s license, therefore a manufacturer can legally distribute its products, the QP named in the Manufacturing License
can take the responsibility for storage and distribution of the product.
As a consequence, there is no need for the manufacturer to name an RP. However, depending on the organization structure and
the complexity of the operation, the company may appoint a person responsible for product distribution.
Each Wholesaler needs an authorization issued by the competent authority of the Member State where the wholesaler is located. Are there any authorizations needed for a warehouse/storage facility?
>> Yes, if a product is stored in a storage facility this facility should be included in either the manufacturers' (Manufacturing License) or
the wholesaler’s license. In the EU, you cannot store products in an unlicensed facility (except at the distribution hub for short durations, e.g. 24 hrs)
Each manufacturer of a medicinal product needs to control and supervise the supply chain (wholesaler, transport and distribution companies etc) of the finished products. Is this
in the responsibility of the Qualified Person of the manufacturer of the medicinal product?
>> The Owner of the product in the supply chain is responsible for its management in the supply chain, if the manufacturer owns the product in the supply chain, then their QP is normally responsible for the product in the supply chain. Of course this responsibility can be delegated to another QP or an RP, but the ultimate responsibility will remain
in the hands of the product QP.
I've heard about a requirement that medicinal products should not be stored for more than 24 hours because in that case the facility would need to have a licence. What is the reference for this requirement?
>> Chapter 9 of EU GDP (Last Paragraph) states ‘ Provision should be made to minimize the duration of temporary storage while awaiting the next stage of the transportation route’ this duration should be specified in companies SOPs based on risk assessment. The current industry practice is 24-72 hours storage at temporary facilities. Longer storage periods are classed as long term storage of product and the facility must have a licence to operate.
As a manufacturer of finished medicinal products, do I need to audit all transport organisations, all warehouses and all wholesalers who will handle my products? What about transportation hubs e.g. at airports. There might be hundreds of such facilities.
>> The Current EU GDP requires manufacturers to have audited and approved all their outsourced activities and have a technical/quality agreement with their service providers. The approach to selection and approval of these facilities should be supported by risk assessment, companies can use shared audits or ‘paper audit’ depending on the complexity of operations and sensitivity of the products involved.
1) Does the EU GDP Guide cover both Human Medicinal Products and Veterinary Medicinal Products?
The full text of the EU GDP Guide provides the answer: Guidelines of 5 November 2013 on Good Distribution Practice of medicinal products for human use (2013/C 343/01). This means Veterinary Products are not covered but it might be useful to adopt GDP principles based on a risk assessment on a voluntary basis.
2) Does the EU GDP Guide cover Investigational Medicinal Products (IMPs) and Radiopharmaceuticals?
The GDP Guidelines focus on wholesale distribution of medicinal products. And IMPs are normally not distributed via wholesalers. However IMPs are not particularly excluded. The Guideline may therefore give some guidance on how to supply clinical trail material. More detailed guidance might be given by the Questions and Answers section of the European Medicines Agency. In the part on supplementary requirements, Annex 13 a few Q&As are dealing with storage and transportation of IMPs.
Radiopharmaceuticals are Medicinal Products and therefore within the scope of the EU GDP Guideline. The GDP Guideline contains a reference to them: “Medicinal products comprising highly active and radioactive materials should be transported in safe, dedicated and secure containers and vehicles.”
3) Are there any GDP requirements for APIs and Excipients in place?
Good Distribution Practice of Active Pharmaceutical Ingredients (APIs) is covered in a separate Guideline. The requirements can be found in: Guidelines of 19 March 2015 on principles of Good Distribution Practice of active substances for medicinal products for human use. These requirements are legally binding in Europe. For Excipients there is no such regulation in Europe. However, an industry standard exists and should be applied on a risk based approach: IPEC Good Distribution Practices Guide for Pharmaceutical Excipients.
4) Is Transportation covered by the EU GDP Guide and can Transport companies receive a GDP Certificate?
This question has been addressed by the EU Commission in a Q&A paper: “Transport companies do not need to hold a wholesale distribution authorisation to transport medicinal products. However, they should follow the parts of the GDP guideline relevant to their activities, amongst others Chapter 9.” Therefore Transport companies need to follow GDP but will not receive a GDP certificate. GDP should be assessed by the customers who ship medicinal products with certain transport companies.
5) Who does issue a GDP Certificate?
The so called competent authorities in Europe have to issue the GDP certificate. Please find here a list of the competent authorities. The details (including the exact procedure and documentation) of the GDP Inspection and Certification is defined in the EMA/EU Commission: Compilation of Community Procedures on Inspections and Exchange of Information.
According to the document: “The contents of the initial inspection report should be sent to the company for its comments to enable the report to be finalised within the relevant timeframe of the inspection request and to enable, if applicable, the issue of a GDP certificate within the statutory 90-day timeframe…… The GDP certificate or the non-compliance statement shall be entered in the Union database referred to in Article 111(6) of Directive 2001/83/EC……The intervals between inspections should be set at a level that provides confidence that the wholesale distributor maintains continued compliance with GDP and its principles. The maximum period between inspections per site should not exceed 5 years as lack of continuity may give rise to lower awareness of current GDP or allow significant deficiencies to develop”.
6) Are Transport Hubs covered by EU GDP?
Hubs are sometimes needed to store goods for a short time period, e.g. in order to collect goods for further shipment. Hubs can be found at airports and usually store products between 24 and 72 hours. They are not intended to store products for a longer time. Chapter 9 of EU GDP (Last Paragraph) states: Provision should be made to minimize the duration of temporary storage while awaiting the next stage of the transportation route.
This duration should be specified in companies' SOPs based on risk assessment. The current industry practice is 24-72 hours storage at temporary facilities. Longer storage periods are classed as long term storage of product and the facility must have a licence to operate. This means that Hubs will not have a GDP certificate but will need to comply with EU GDP based on a risk assessment.