Professional Documents
Culture Documents
品質リスクマネジメント
prepared by members of the ICH Q9 EWG slide 1 , July 11, 2006
Layout Draft
ICH Q9: Quality Risk Management
ICH Q9 QUALITY RISK MANAGEMENT
The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9.
It was prepared by some members of the ICH Q9 EWG for example only. It has not gone
through any ICH formal process. It does not represent an official policy/guidance.
Quality Risk Management ICH Q9
Briefing Pack
Introduction
ICH Q9 together with ICH Q8 and Q10 is one of the ICH Q-topics that encourage
further development science based and risk based approaches to quality. The
intention of ICH Q9 is to focus the behaviours of industry and regulatory
authorities on the two primary principles of Quality Risk Management, which are:
Briefing Pack
Disclaimer:
The Q9 briefing pack is offered as a supplementary explanation of the material in
ICH Q9. It was prepared by some members of the ICH Q9 EWG for example only.
It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
Quality Risk Management ICH Q9
Briefing Pack
Failure Mode Effects (Criticality) Analysis (FMEA & FMECA) HTML PPT
For creating paper copies of a manual with all slides see the Acrobat (pdf) version
Disclaimer:
The Q9 briefing pack is offered as a supplementary explanation of the material in
ICH Q9. It was prepared by some members of the ICH Q9 EWG for example only.
It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
Team recruited from the
Members of the Expert Working Group:
Writers
Stephan Rönninger (Chair) F. Hoffmann-La Roche Ltd
Gregg Claycamp FDA
formerly with Eli Lilly Inc.; David Begg
Peter Gough
Associates
Malcolm Holmes Glaxosmithkline
Takayoshi Matsumura Eisai Co. Ltd
Christine Mundkur Barr Laboratories
Tetsuhito Takarada Mochida Pharmaceutical Co. Ltd
Hideki Sasaki Nippon Shinyaku Co. Ltd
Reviewers
Emer Cooke EMEA
Diana Dowthwaite Health Canada
Albinus D'Sa FDA
Gregg Guyer Merck& Co. Inc.
David Horowitz FDA
Yukio Hiyama MHLW
Georgia Keresty Centocor
Sabine Kopp WHO
Urs Kopp Swissmedic
Agence Française de Sécurité
Jacques Morenas Sanitaire des Produits de Santé -
AFSSAPS
Markus Müller Swissmedic
Etienne Ouimette Health Canada
Consumer Health Care Products
Fred Razzaghi
Association
Process
Incremental steps Understanding
Process Process
Pharmaceutical Development (Q8) Understanding Understanding
CMCCMC
regulatory
Changed Past: Data transfer / Variable output regulatory
Oversight CMCCMCregulatory
Paradigm Present: Knowledge transfer / Science
(Submission)
oversight Oversight
regulatory
CMC
(Submission)
oversight
based / Consistent output regulatory
oversight
cGMP cGMP
regulatory
cGMPcGMP
regulatory
Quality Risk Management (Q9)
regulatory
oversight
(Inspection)
oversight
Q8 regulatory
oversight Q10 cGMP
regulatory
& &
(Inspections)
oversight oversight
Improvement Risk
Improvement
Future: Quality Systems across product Risk
Q9
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 1
Executive summary Executive summary
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Pharmaceutical industry and quality risk management Advantages of quality risk management as technique
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 2
Executive summary Executive summary
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
• Ensure organisation is aware of ICH Q9 • ICH Q9, together with “Pharmaceutical development”
and the opportunity it affords (ICH Q8) and “Quality systems” (ICH Q10), provides
opportunity for a revised, optimised and, less restrictive
> Appropriate education and training
regulatory paradigm
• Encourage open, risk aware culture > Based on scientific knowledge
> Establish & support “QRM leaders” across organisations > Enable continuous improvement
> Greater transparency and efficiency
• Encourage integration of Quality Risk Management
> Focusing on things that add value for patients
with existing Quality systems
> Improved relationship between industry and competent
> Do NOT set up as a separate department
authorities based on trust
> Coordinate implementation and resource allocation
• We must seize this opportunity
> Prioritise; start small, learn as you go
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 13 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 14
ICH Q9
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 15 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 16
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 3
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Risk Management
the background
of the ICH Q9 document
Background
Disclaimer: This presentation includes the authors views on quality risk management theory and practice.
The presentation does not represent official guidance or policy of authorities or industry.
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 19 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 20
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Agenda Agenda
• ICH Q9 and other ICH guidelines • ICH Q9 and other ICH guidelines
• From “Risk” to “Quality Risk Management” • From “Risk” to “Quality Risk Management”
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 21 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 22
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
on Harmonisation
of Technical
Guidelines on
Requirements Expert Working
Groups (EWG)
Quality
Chemical and
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 23 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 24
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 4
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
• Q1 Stability
• The ICH process
• Q2 Analytical Validation
• Q3 Impurities
• ICH Q9 and other ICH guidelines • Q4 Pharmacopoeias
• Q5 Quality of Biotechnological Products
• From “Risk” to “Quality Risk Management” • Q6 Specifications
• Q7 Good Manufacturing Practice
• Opportunities, Challenges and Benefit • Q8 Pharmaceutical Development
Different:
• Q9 Quality Risk Management - not a recipe
• Q10 Pharmaceutical Quality Systems - not a “SOP”
just a guidance
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 25 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 26
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 5
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Q10
Q9
Q8
Q 10 Future: Quality Systems across product
Q9
life cycle
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 31 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 32
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
How Q9 interacts with Q8 and Q10 ICH Q9 Link back to patient risk
Opportunities to impact
Risk from Manufacturing site
Design management Q9
t
en
em
ov
Process
pr
m
li
ua
Quality Risk
co
Management Facilities
Distribution
principles
Low Q8 Pharmaceutical Development
Patient
Low High
Product / Process Risk Q8 Q10
Base: J. Ramsbotham, Solvay Pharm. NL / EFPIA G.- Claycamp, FDA, June 2006
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 33 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 34
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Process
A Vision of the future becomes fact Understanding
Process Process
Understanding Understanding
Old Approach New Approach Remarks CMCCMC
regulatory
regulatory
Oversight CMCCMCregulatory
Quality decisions divorced Quality decisions and filing Design Space concept (Submission)
oversight Oversight
regulatory
from science and risk committments based on introduced to integrate CMC
(Submission)
oversight
Broad Concept evaluation. Process Understanding process knowledge with regulatory
oversight
Adherence to filing and Risk Management. regulatory evaluation. cGMP cGMP
regulatory
cGMPcGMP
regulatory
commitments.
Post-factum sampling and
Quality by Design.
Management of variability Quality by design definition
regulatory
oversight
(Inspection)
oversight
Q8 regulatory
oversight Q10 cGMP
regulatory
& &
quality testing. Process control focused on applied. Measure critical (Inspections)
oversight oversight
Quality Process Validation. critical attributes. process parameters to control
Continuous Quality
Verification.
output product quality.
Company’s Q9 Company’s Q9 Company’s
Systems designed to inhibit Changes managed within Regulators and industry place Quality system Quality system Quality system
changes & minimize business company's quality system. higher reliance / trust /
Systems risks. Discourages Real time batch release understanding on systems. Post
Continuous
improvement & innovation. feasible. Multidisciplinary evaluation Approval
approval
Change
PAC
PAC toto Improvement
and decision making. change
(PAC)
Compliance focus. Regulatory scrutiny adjusted Requires mechanisms to Continuous
Continuous
Improvement Risk
Changes require prior to level of Process communicate Process Improvement
Regulatory approval. Understanding. Continuous
improvement allowed
Understanding data
("inspectable rather than
Risk
(perceived Risk
within Design Space. reviewable") . (P/R)& real)
Based on EFPIA, PAT Topic Group, 2005 Based on A.Hussain, FDA, September 2004
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 35 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 36
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 6
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Agenda
ICH Q9
• The ICH process
Quality Risk Management
• ICH Q9 and other ICH guidelines
What does it mean?
• From “Risk” to “Quality Risk Management”
What is it worth?
• Opportunities, Challenges and Benefit Where does it lead?
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 37 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 38
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
?
for best practice,
transparency and Improve
compliance • Globalisation Proactive Quality
“Multinational” communication
• Public / Community
• Governments • Multi-factor approaches
disclosure Risk through sharing best
build trust and
• Regulators
• Patients
• Regulatory expectations
• Acceptance of understanding Management practice and science
risk and uncertainty
based knowledge
• Investors / Creditors
Increasing
efforts and costs •• Documentation Master complexity
Projects
for sustainability • Systems
Convert data into knowledge
• Interfaces e.g. by using methodology and tools
Based on D. Geller, Roche Based on D. Geller, Roche
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 41 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 42
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 7
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
y
> 30% of the days like tomorrow will have at least a trace of rain.
lit
bi
> 30% of the area will have rain tomorrow. lo
ta
w
ec
t
> 30% of the time tomorrow, it will rain.
de
Gigerenzer, et. al (2005) ris
k severity
G. Claycamp, FDA, September 2005
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 45 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 46
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Probability x Detectability x Severity • Keep a robust data set for further evaluation!
> Is the data set comparable?
> Are the data plain and concise?
Refers to
Refers to
Refers to
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 8
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Process Parameter Æ
Potential threat
- chemical reaction product quality or Upper Specification Limit (USL) Uncertainty
- manufacturing issues
- facilities and equipment the business
(loss, interruption, image)
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Tomorrow ?
Tomorrow ?
Process Parameter Æ
Process Parameter Æ
Uncertainty Uncertainty
Time Æ today
Time Æ Take a cut today
at a
RISK: Control options are scenarios for risk management. Note moment in time:
that this scenario shows the best estimate is below the USL. Risk has a distribution.
G. Claycamp, FDA, Sept. 2005 G. Claycamp, FDA, Sept. 2005
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 51 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 52
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 9
Background Background
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
> How good is our QRM compliance and decision making? • WHO Technical Report Series No 908, 2003 Annex 7 Application
of Hazard Analysis and Critical Control Point (HACCP)
> To what extent QRM has to be implemented or formalised? methodology to pharmaceuticals
• GAMP Good Practice Guide ISPE, 2005
• An then focus efforts and communicate in order to… A risk-based approach to compliant electronic records and
> Avoid duplication of effort and to align initiatives signatures
> Develop scope by using different viewpoints • ISO 14971:2000 - Application of Risk Management
to Medical Devices
e.g. from management, internal and external customers
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 55 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 56
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Risk Assessment
• The ICH Q9 document:
Risk Identification
> Main body explains the “What?”
Risk Analysis > Annex I give ideas on the “How?”
Risk Evaluation > Annex II give ideas on the “Where?”
unacceptable
Risk Management tools
Risk Communication
Risk Control
• It can be implemented by industry and regulators
Risk Reduction
> Pharmaceutical development (ICH Q8) and Quality Systems
Risk Acceptance
(ICH Q10) will facilitate the “What?”, “How?” and “Where?”
Output / Result of the • “It helps prevent overly restrictive and unnecessary
requirements being imposed by either industry or
Quality Risk Management Process
Risk Review
regulators” (ICH Q9)
Review Events
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 57 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 58
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 10
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Using QRM
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 61 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 62
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Gain experience
• The ICH process
Analyse root cause: (Risk of) Failure ?
Continuous Manufacture
• ICH Q9 and other ICH guidelines improvement for market
Quality Risk
Management
• From “Risk” to “Quality Risk Management” Improve it (QRM) Do, what you say
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Risk Management & Flexibility QRM may help define acceptable quality levels
• Definitions of “Compliance”:
> Conformity in fulfilling official requirements
Use
> The act or process of complying to a
“science-based” and
desire, demand, or proposal or to coercion “risk-based” behavior
> A disposition to yield to others
> The ability of an object to yield elastically • Not every single detail can nor should be covered by
when a force is applied: flexibility
> Specifications (product quality)
> Documents (quality systems)
• Definition of “Flexibility”:
> characterised by a ready capability • Set priorities and allocate resources
to adapt to new, different, or changing requirements according to the potential for protection of patients
Source: www.webster.com, 01. Nov.04
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 65 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 66
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 11
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
• Using the same guideline apply QRM to • Over all: Positive Contribution to patient protection
> Industry (development, manufacture and distribution) > Further develops Quality Risk Management awareness,
> Competent authorities (reviewer and inspectorate) that is already part of industry and regulatory culture
• Facilitates common approaches to quality risk • Ongoing change in behaviour
management in our every day jobs
> Identifying risks can be positive
• Supports science-based decision making > A long list of identified risks that are assessed and
controlled provides high quality capability
• Focus resources based on risks to patients
• Awareness of quality risks
• Avoids restrictive and unnecessary requirements
> “Risk-based approach”
• Facilitates communication and transparency > A potential of risks remains - No “Zero” risk!
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 67 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 68
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
> Develop training on methods and tools, as appropriate • Encourages a preventive approach
> Proactive control of risks and uncertainty
> Do not create new QRM organisations > Benefit of knowledge transfer by team approach
> Do not create new requirements • Changes behavior
• Adapt existing requirements using quality risk > Better understanding of risk-based decisions
management behaviors > Acceptance of residual risks
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 69 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 70
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 71 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 72
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 12
Background Background
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
From tick-box
Doing things,
approach for compliance
that do not matter
towards
systematic for the patient
risk-based thinking
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 73 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 74
Background
ICH Q9 QUALITY RISK MANAGEMENT
Integration of QRM
into existing systems
and
regulatory processes
will take time, trust and
communication
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 75
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 13
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Disclaimer: This presentation includes the authors views on quality risk management theory and practice.
The presentation does not represent official guidance or policy of authorities or industry.
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 79 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 80
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Nov. 2005
Step 4 Agreement of the 3 ICH regulators and
2006 Chicago "Signed off" by ICH Steering Committee
Not legally binding,
unless incorporated in local law
Draft for consultation Chicago ICH Q9 2006 Step 5 Implementation within the 3 Regions
2005 ongoing
March 2005 November 2005
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 81 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 82
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
ICH Concept paper Osaka, November 2003 Result of ICH Q9 EWG Meeting London, March 2004
• Technology focus
• A draft table of contents, flow diagram, definitions
> Increase process capability were agreed
> Focus on critical control points
• Assignments to produce first drafts
• Product
of the full text for each section
> Stabilise manufacturing steps (decrease variability) of the draft table of contents were agreed
> Guarantee shelf-life
• People • Started the dialogue with the ICH Q8 EWG
> Result in a superior performance of the Q-System • Regulatory flexibility
• Customer > The degree to which the final versions of both Q9 and Q8
> Reduce deviation could refer to 'regulatory relief' was a debate on principles.
> Reduce market complaint rate > Term changed to “regulatory flexibility” or “risk
confidence”.
> Reduce technical related adverse events
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 83 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 84
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 14
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Result of ICH Q9 EWG Telecon September 2004 Result of ICH Q9 EWG Meeting November 2004
• Optional nature of ICH Q9 to be emphasized • Milestone: Draft 4 issued as “pre-step 2” document
• All EWG parties want to push ICH Q9 forward • Major concerns were addressed and resolved
> No support for delaying ICH Q9 • Primary principle: link back to the potential harm to
the patient
• Appointments for redrafting in six groups
• Integration of QRM into existing systems & regulatory
> Subgroup decide on details of Chapter 5 / 6 as annex or not
processes will take time
> One subgroup to deal with ICH Q8 relationships
• For more details:
• Case studies: Peter Gough and Stephan Roenninger,
> Which ones are appropriate to use in ICH Q8, Q9 or Q10? ICH Q9 : Quality Risk Management - an update
> Everybody should decide, whether the case studies should Regulatory Affairs Journal, 16, 2005, 91-93
be included as an annex in the ICH Q9 document or used as
training material - Decision to be made in Yokohama
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 87 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 88
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Result of ICH Q9 EWG Telecon February, 22 2005 ICH Q9 Expert Working Group (EWG) as of ICH Step 2
• All EWG parties agreed Mr. David Horowitz Dr. Greg Guyer (Rapporteur)
to put Q9 forward to step 2
Director, Office of Compliance, CDER Merck &Co, Vice President, MMD QA
Dr. H. Gregg Claycamp Dr. Georgia Keresty
Director Scientific Support Staff Centocor, Inc.,GlobalBiologicsSupply
Vice President, Worldwide Quality
Ms. Diana Kolaitis
District field inspector
Mr. Jon Edward Clarke
Dr. Yukio Hiyama FDA HFD (alternate: Q8) Ms. Emer Cooke
Head of sector Inspections EMEA
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 89 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 90
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 15
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
• Move “continuous improvement” to Annex II.1 (see ICH Q10) Yukio Saito
GMP Inspector, PMDA
Takashi Nagashima
GMP Expert, PMDA Ms. Diana Dowthwaite
• Reduce complexity by combining and re-wording the
Compliance and Enforcement Coordination division, Mr. Malcolm Holmes
Health prod. & Food Branch Inspectorate Health CDN GSK, UK, Global Quality Assurance, Director
Ms. Christine Mundkur Dr. Stephan Rönninger
individual sections
International Generic Pharmaceutical Alliance F.Hoffmann-La Roche, CH, Global Quality Manager
Mr. Frederick Razzaghi
Consumer Health Product Association
Mr. Takayoshi Matsumura Dr. Sabine Kopp
> “formal” and “informal” risk management referenced Eisai, Assistant Manager, Corporate QA Department
Mr. Tetsuhito Takarada
QA & Safety Medicines, WHO
Dr. Markus-Peter Müller
Head of QM-Inspectorate, Swissmedic
Mochida Pharm.Deputy Director, Quality Control
Mr. Hideo Sasaki
> “detectability” as an element in several chapters Nippon Shinyaka Co Ltd, Manager Anal.Chem.Sect.
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 91 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 92
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
History History
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 16
History Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Quality
Risk Management
Optional ICH Q9
but can benefit
from its use!
Content
Disclaimer: This presentation includes the authors views on quality risk management theory and practice.
The presentation does not represent official guidance or policy of authorities or industry.
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 97 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 98
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 99 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 100
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 17
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
2. Scope 2. Scope
This guideline provides • Drug substances,
principles & examples of tools • Drug (medicinal) products,
of quality risk management that can be applied to • Biological and biotechnological products
different aspects of pharmaceutical quality.
Including the selection and use of
These aspects include development, manufacturing,
> Raw materials
distribution, and the inspection and submission/review > Solvents
processes throughout the lifecycle > Excipients
of drug substances, drug (medicinal) products, > Packaging and labelling materials
biological and biotechnological products > Components
ICH Q9
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 103 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 104
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
ICH Q9 ICH Q9
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 105 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 106
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
4. A General Initiate
Quality Risk Management Process 4. General Quality Risk Management Process
Quality
Decision makers:
Risk Assessment
Risk Control
Risk Acceptance
• Coordinating
Team Output / Result of the quality risk management process
approach Quality Risk Management Process
across various functions and departments
Risk Review
Review Events
• Supporting
ICH
ICH Q9 Q9 the team approach
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 107 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 108
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 18
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Team approach When to initiate and plan a QRM Process
• Usually, but not always, undertaken by interdisciplinary • First define the question which should be answered
teams from areas appropriate to the risk being (e.g. a problem and/or risk question)
considered e.g. > including pertinent assumptions identifying
> Quality unit the potential for risk
> Development
> Engineering / Statistics • Then assemble background information and/ or data
> Regulatory affairs on the potential hazard, harm or human health impact
> Production operations relevant to the risk
> Business, Sales and Marketing
> Identify a leader and necessary resources Initiate Quality
> Legal
Risk Manage ment Process
Risk Assessme nt
Risk Identification
> Medical / Clinical > Specify a timeline, deliverables and Risk Analysis
Risk Evaluation
Risk Acceptance
Risk Review
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 109 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 110
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
When to apply Quality Risk Management? 4. General Quality Risk Management Process
Should risks
be assessed? Risk Assessment
1. What might go wrong?
2. What is the likelihood (probability) 3 fundamental
Are there clear rules it will go wrong? • Risk Identification
for decision making?
No or 3. What are the consequences (severity)? questions
e.g. regulations
justification needed
What might go wrong?
Can you answer
the risk assessment
questions? No
• Risk Analysis
“formal RM“
What is the likelihood (probability) it will go wrong?
Yes Agree on a team
Yes
“no RM“
“informal RM“ (small project)
• Risk Evaluation
Risk assessment not required Initiate Risk assessment Select a Risk Management tool What are the consequences (severity)?
(No flexibility) (risk identification, analysis & evaluation) (if appropriate e.g. see ICH Q9 Annex I)
Risk Analysis
Risk Control
Risk Review
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 111 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 112
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Risk Assessment: Risk Identification Risk Assessment: Risk Analysis
unacceptable unacceptable
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 113 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 114
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 19
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Risk Assessment: Risk Analysis Risk Assessment: Risk Evaluation
Often data driven
Keep in mind: “What is the risk?”
Statistical approach may or may not be used
• Compare the identified and analysed risk
• Maintain a robust data set! against given risk criteria
• Start with the more extensive data set and reduce it
• Consider the strength of evidence
• Trend and use statistics (e.g. extrapolation) for all three of the fundamental questions
• Comparing between different sets requires > What might go wrong?
compatible data
Initiate Quality
Initiate Quality
Risk Manage ment Process
Risk Analysis
Risk Analysis
Risk Control
Risk Control
Risk Reduction
Risk Reduction
Risk Acceptance
Risk Acceptance
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 115 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 116
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Risk Assessment: Risk Evaluation Risk Control: Decision-making activity
A picture of the life cycle = Risk Priority Number
• Is the risk above an acceptable level?
Probability x Detectability x Severity • What can be done to reduce or eliminate risks?
Can you find it?
• Frequency of
“occurences” between benefits, risks and resources?
Impact
driven by
the number • Are new risks introduced as
of trials
• Degree a result of the identified Initiate Quality
Risk Manage ment Process
of belief
Risk Identification
Risk Analysis
Risk Evaluation
Risk Control
Risk Reduction
Risk Acceptance
Risk Review
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 117 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 118
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Risk Control: Residual Risk Risk Control: Risk Reduction
of existing risks
Risk Analysis
Risk Evaluation
Risk Management t ools
Risk Evaluation
Risk Comm unication
unacceptable
Risk Management t ools
Risk Comm uni cation
unacceptable
Risk Control
Risk Control
Risk Reduction
Risk Acceptance
Risk Acceptance
ICH Q9
Review Events
Review Events
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 119 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 120
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 20
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Risk Control: Risk Acceptance Risk Control: Risk Acceptance
• Decision to
• Discuss the appropriate balance between
> Accept the residual risk benefits, risks, and resources
> Passively accept non specified residual risks
• Focus on the patients’ interests and
good science/data
• May require support by (senior) management
• Risk acceptance is not
> Applies to both industry and competent authorities > Inappropriately interpreting
Initiate Quality
Risk Manage ment Process Initiate Quality
Risk Manage ment Process
Risk Analysis
Risk Analysis
Risk Evaluation
Risk Acceptance
Risk Acceptance
Risk Review
Review Events
competent authorities Output / Result of the Quality
Risk Manage ment Process
Risk Review
Review Events
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 121 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 122
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT EXAMPLE
No Risk Assessme nt
Risk Control
Risk Review
Review Events
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 123 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 124
Content Content
ICH Q9 QUALITY RISK MANAGEMENT EXAMPLE ICH Q9 QUALITY RISK MANAGEMENT EXAMPLE
A Risk No
Revisit
risk assessment step
No
Accept the
residual risk?
Yes
Advantage
outweighs risk?
Measures / Actions Revisit
Acceptance appropriate?
No
risk reduction step
Yes No
process Yes Accept risk Risk not acceptable
2/3 Sign off documentation Sign off documentation
Other hazards
Yes
caused?
Initiate Quality Initiate Quality
Risk Manage ment Process Risk Manage ment Process
unacceptable unacceptable
reducible?
Output / Result of the Quality Output / Result of the Quality
Risk Manage ment Process Risk Manage ment Process
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 125 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 126
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 21
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
4. General Quality Risk Management Process 4. General Quality Risk Management Process
Risk Communication Risk Communication
• Bi-directional sharing of information
about risk and risk management • Exchange or sharing of information, as appropriate
between the decision makers and others
• Communicate at any stage of the QRM process • Sometimes formal sometimes informal
• Communicate and document > Improve ways of thinking and communicating
the output/result of the QRM process appropriately
• Communication need not be carried out • Increase transparency
for each and every individual risk acceptance
Initiate Quality Initiate Quality
Risk Manage ment Process Risk Manage ment Process
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 127 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 128
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
- Inspections - Manufacturing
Risk Assessme nt
Risk Identification
Risk Analysis
Risk Evaluation
Risk Control
Risk Reduction
Risk Acceptance
Risk Review
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 129 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 130
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS
Risk Assessme nt
Risk Identification
Risk Analysis
Risk Evaluation
unacceptable
Risk Control
Risk Reduction
Risk Review
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 131 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 132
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 22
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
sometimes detectability
Risk Manage ment Process
Risk Analysis
Risk Evaluation
Risk Control
Risk Acceptance
Risk Review
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 133 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 134
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Risk Analysis
Risk Evaluation
Risk Management t ools
internal procedures
Risk Control Risk Control
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 135 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 136
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
Overview: Some tools and their key words 5. Risk Management Methodology
• Failure Mode Effects Analysis (FMEA) • Supporting statistical tools
> Break down large complex processes into manageable steps
• Failure Mode, Effects and Criticality Analysis (FMECA) > Acceptance Control Charts (see ISO 7966)
> FMEA & links severity, probability & detectability to criticality > Control Charts (for example)
¾ Control Charts with Arithmetic Average and
• Fault Tree Analysis (FTA)
Warning Limits (see ISO 7873)
> Tree of failure modes combinations with logical operators ¾ Cumulative Sum Charts; “CuSum” (see ISO 7871)
• Hazard Analysis and Critical Control Points (HACCP) ¾ Shewhart Control Charts (see ISO 8258)
> Systematic, proactive, and preventive method on criticality ¾ Weighted Moving Average
• Hazard Operability Analysis (HAZOP) > Design of Experiments (DOE)
> Brainstorming technique ¾ Pareto Charts
• Preliminary Hazard Analysis (PHA) Risk Assessme nt
Initiate Quality
Risk Manage ment Process
Risk Identification
> Process Capability Analysis
Initiate Quality
Risk Manage ment Process
Risk Assessme nt
Risk Identification
> Possibilities that the risk event happens Risk Analysis Risk Analysis
> Histograms
Risk Evaluation Risk Evaluation
Risk Mana ge me nt t ools
unacceptable unacceptable
> Compare and prioritize risks with factors for each risk Risk Review
Output / Result of the Quality
Risk Manage ment Process
> Use others that you are familiar with…. Output / Result of the Quality
Risk Manage ment Process
Risk Review
Review Events
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 137 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 138
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 23
Content Content
ICH Q9 QUALITY RISK MANAGEMENT CONSIDERATIONS ICH Q9 QUALITY RISK MANAGEMENT
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Annex II: Potential Applications for QRM Annex II: Potential Applications for QRM
This Annex is intended to identify potential uses of Quality risk management as part of
quality risk management principles and tools by • Integrated quality management
industry and regulators.
> Documentation Competent
However, the selection of particular risk management authorities
> Training and education
tools is completely dependent upon specific facts and
circumstances. > Quality defects
Industry
These examples are provided for illustrative purposes and > Auditing / Inspection
only suggest potential uses of quality risk management. > Periodic review
This Annex is not intended to create any new > Change management / change control
expectations beyond the current regulatory requirements. > Continual improvement
ICH Q9 Introduction to Annex II
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 141 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 142
Content Content
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
RE
ER IT
Quality risk management as part of SE V TIO
N K)
TE
ACCEPT
D EA
BIL IDE
IS M
BA
T
C S
O
T`?
IP
W
AR
authorities
PROCESS
Y
> Inspection and assessment activities Fault Tree Analysis FTA ASSESSMENT
FMECA N
Failure Mode, Effects & Criticality Analysis INSPECTIO
LATORY
Failure Mode Effect Analysis FMEA REGU
ICH Q9
• Industry operations TIO N U
HAZOP TOOLS APPLICA Q PRODUCTION
Hazard Operatibility Analysis Quality Risk INDU
ST RY
HACCP MATERIALS
Management
> Development
Hazard Analysis & Critical Control Points
L QUAL
INFORMA ITY Mg CHAN
K PR GE CO
LE TRAINING
RD
Y S
ERIT
> Materials management
PATIE DOC
SEV
ZA
NT PR UMEN
M OTEC TA
HA
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 24
Content Initiate
Quality Risk Management Process
Frequently Asked Questions (FAQ)
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
Risk Assessment
Risk Identification
Risk Analysis
Quality
Risk Evaluation
unacceptable
Risk Management
Risk Control
Risk Reduction
Risk Acceptance
ICH Q9
Output / Result of the
Quality Risk Management Process
Frequently Asked
Risk Review
Existing
• It can be implemented by industry and competent d
internal ase
k-b ch
authorities (reviewers and inspectorates) documentation Where Ris proa r
ng
to be in ap e
al risk
t h nt
ki
residu ble
system id
in
se me
Co CH
ba ple
(Mission, Policy)
d
ls
I
A
too
E
ific or
What to do?
M
f
e.g. F
s
(e.g. Directives)
ple
list of
ec
How to do?
> Pharmaceutical Development (ICH Q8) and
in g
(e.g. Guidelines)
Quality Systems (ICH Q10) will facilitate the use of Q9
Detailed instructions
• Do not set up a QRM department (e.g. Standard Operating Procedures)
Records
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 25
Frequently Asked Questions (FAQ) Frequently Asked Questions (FAQ)
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
• The level of detail and quantification needed • This has to be decided in the context of each
helps to determine the tool to use: specific risk management problem
> Methodology • If you put in precise and definite data, you will receive
e.g. formal or informal risk management process a clear answer. This enables decision makers to make
> System risks good and transparent decisions
e.g. risk ranking and filtering, FMEA
• Accept residual risk, where further effort to reduce a
> Process risks
e.g. FMEA, HACCP, process mapping, flow charts risk is disproportional to the protection of the patient
> Product risks • Always remember: The protection of the patient
e.g. flow charts, decision trees, tables, check sheets
• It’s up to the organization whether they accept risks
that meet the principles of QRM
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 151 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 152
What is the content of the “output/result” box? When to stop a QRM process?
• When you decide, through a risk management process,
• The rationale and output have to be communicated that a certain residual risk is acceptable,
after decision making you can close your QRM process for that particular risk
> The means and records of what is communicated > You should communicate the outcomes on that QRM
will vary in individual circumstances process, as appropriate, to stakeholders
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 26
Frequently Asked Questions (FAQ) Frequently Asked Questions (FAQ)
ICH Q9 QUALITY RISK MANAGEMENT ICH Q9 QUALITY RISK MANAGEMENT
How will Q9 be involved in the submission Will ICH Q9 be applied by competent authorities as
and review process? they develop / review regulations?
Q9 supports presentation of scientific arguments: • There have already references been made to the use
of ICH Q9 principles in recent regulatory documents.
• For proposals in the submission This indicates the awareness and commitment to ICH
Q9 in some competent authorities
• For answering subsequent questions and • There are some existing and proposed regulations
proposals the reviewers may raise which do not recognise the use of ICH Q9 principles.
It is the hope and expectation that this will be taken
• When linked with “Pharmaceutical development” into account as the opportunity arises for revision or
(ICH Q8) it might avoid the need for such questions prior to publication
by reviewers
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 157 prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 158
prepared by some members of the ICH Q9 EWG for example only; not an official policy/guidance July 2006, slide 161
Disclaimer: The ICH Q9 briefing pack is offered as a supplementary explanation of the material in ICH Q9. It was prepared by some
members of the ICH Q9 EWG for example only. It has not gone through any ICH formal process. It does not represent an official
policy/guidance.
ICH Q9 Briefing pack I, July 2006, page 27