Category IAG

MHRA Inspectorate Blog has recently published Part 2 in the Compliance Monitor Process series with further information about the Compliance Monitor (CM) role and application process.

The blog can be found here: Compliance Monitor Process (Part 2)– CM role and application process

The blog acknowledges that it is common for companies that are at IAG to employ consultants to assist with remediation activities, and this is something that EPiC has extensive experience of supporting including reporting on progress to MHRA. The application process for an individual to apply for the CM pilot programme to be named on a register will be based on an eligibility assessment by MHRA considering career history, relevant experience, not having been personally the subject of MHRA regulatory action and/or significant adverse findings in the previous 3 years, and the need to have completed relevant training in the CM process. Eligible CM’s will then be assessed by MHRA for suitability on a case-by-case basis when they are nominated by a company, to confirm that they have sufficient experience of the dosage forms and site operations and that there is no conflict of interest. 

In response to the recent MHRA Inspectorate Blog post, Richard Andrews commented “It is good to see that both eligibility and suitability of the CM are being assessed which draws parallels from the naming of Qualified Persons (QPs) on UK manufacturing licences. Although a QPs eligibility to be named may be assessed by the Joint Professional Bodies, MHRA, or an EU regulator, their suitability to be named on a specific UK manufacturing licence is assessed and decided by MHRA based on site-specific knowledge and experience, which is above and beyond their eligibility assessment. The same two-stage approach will help to ensure CMs will have the background experience and site-specific knowledge to assess risks to product quality and patients in developing and overseeing remediation plans and assisting with implementation. This type of remediation work is a core service we offer at EPiC and is why our consultants will be applying to be named as CMs.”  

Trust us: IAG is not an acronym that you want to be too familiar with. It stands for Inspection Action Group, the multidisciplinary team at the MHRA that determines whether your organisation maintains or loses its manufacturing or wholesale dealers licence.

It may be surprising to some of you that after 50 years plus of pharmaceutical legislation and GMP/GDP regulations that 3-4 companies a month still find themselves being referred to IAG with the potential of having their licences suspended or coming under strict and costly surveillance by the MHRA Compliance Management Team.

However, this is not so surprising to us in the EPIC Auditors team. Most of us are ex MHRA Inspectors, and we know only too well that any change in the Senior Management of a company can have a significant effect on the quality mindset and compliance level of a site.

Hopefully it will be for the better but sadly all too often it is for the worse. Most of the companies that we work with require our help because the quality focus at senior level is inadequate. It is still rare to see a Quality Director on the Board of Directors and this role should be seen as important as that of the Finance Director and Operations Director. If all Senior Management Teams had the Quality training and Quality understanding required to run the business in a cost effective and compliant manner, then we might see a reduction in Inspection Action Group cases at MHRA.

It is our opinion that anyone appointed to a Senior Management Team role should undergo mandatory training in Quality Management and ICH Q 10 principles.  Those companies that we have provided this training for will hopefully endorse our thinking. It is a requirement of GMP that all employees have training in Quality Management and this includes the Senior Management Team. Failures to implement an appropriate Pharmaceutical Quality System and to conduct suitable and effective quality management reviews with the involvement of senior management, feature in the top 10 deficiencies raised by MHRA year on year. Ensuring the Senior Management Team are aware of and are trained in their quality role and responsibilities, should lead to fewer companies facing the threat of IAG.