pharma.regulations

GAMP 5, EU-GMP Annex 11
and 21 CFR Part 11 in
Automated Quality Assurance

In the pharmaceutical and medical technology industries, inspection systems must not only inspect reliably, but also meet regulatory requirements for documentation, data integrity, traceability and validation readiness.

In regulated production environments, machine vision inspection systems are part of a computerized system. For this reason, software, user management, inspection recipes, audit trail, data storage and interfaces must be considered early in the system concept.

With pharma.regulations, OCTUM supports the implementation of automated inspection systems for regulated production processes – technically robust, documentable and aligned with the requirements of GAMP 5, EU GMP Annex 11, EU GMP Annex 15 and 21 CFR Part 11.

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What Do Regulations Mean for Automated Machine Vision?

In regulated production environments, it is not enough for a product to be classified as “good” or “bad”. It is also essential that the inspection result can be documented in a traceable, reproducible and audit-ready manner.

An inspection system must therefore not only solve technical inspection tasks, but also meet requirements for user permissions, change histories, inspection data, interfaces and documentation. OCTUM considers these requirements as early as the system concept phase – from the inspection task through to later integration into the production line.

Overview

Regulations for the automated quality assurance of pharmaceutical products

Automated in-process quality assurance is subject to regulations on three levels. We are familiar with these requirements and offer you peace of mind with maximum quality.

Here, you’ll find an overview of the various applicable regulations and how they fit together: from laws and acts passed by individual countries to directives and also recommendations. With OCTUM, you can trust in a reliable and experienced partner for inline quality assurance with vision inspection systems.

In the European Union, the handling of medical devices and pharmaceutical products is standardised and regulated by the European Medicines Agency (EMA). The EMA publishes guidelines based on EU Commission directives, which are transposed into national law by the medical regulatory bodies of the individual Member States.

A great many regulations and recommendations must be observed during the design and manufacture of automated inspection systems. For example, similarly to CFR 21 Part 11, the EU GMP Annex 11 guideline describes the requirements for computerised systems, but also extends to cover the topics of qualification and validation. The latter is set out in detail in the associated Annex 15 guideline.

The FDA (Food and Drug Administration) is the U.S. authority responsible for the central marketing authorisation and monitoring of pharmaceutical products and medical devices. The FDA monitors the market more proactively than European authorities – with on-site inspections, for example. Therefore, OCTUM solutions are always based on the most stringent rules and regulations.

21 CFR Part 11 is the best known American federal law passed by the FDA in this field. It lays down the requirements for computerised systems that handle pharmaceutical products, among other things. These cover the prerequisites for the reliability and trustworthiness of digital documents, in the same way as traditional records. Part 11 defines the conditions under which the electronic records and signatures of computerised systems can be considered trustworthy and reliable. Certain other parts of 21 CFR also have to be observed.

The “Good Automated Manufacturing Practice 5” guideline is regarded as the standard regulatory volume for the validation of computerised systems in pharmaceutical and medical technology. It lays down requirements for planning, commissioning, validation and qualification – of production systems, for example. The guideline is published by the International Society of Pharmaceutical Engineers (ISPE), which has committees including representatives from medical regulatory bodies and experts from the pharmaceuticals industry.

The GAMP5 is not a law, but rather a recommended methodology for developing a compliant computerised system. The GAMP5 Software Development Life Cycle describes the requirements from the planning to the productive operation of automated systems, under consideration of all the expected risks.

In practice, the system’s function (FS) and design (DS) are conceived with direct reference to the URS (User Requirement Specification). Following a specific risk analysis, the system is implemented and put into operation in the machine. During the subsequent qualification phase, the Installation, Operational and Performance Qualification (IQ/OQ/PQ) process verifies and records whether the overall system complies with the specifications.

Inspection systems from OCTUM have been specially developed for the pharmaceuticals industry and have been an established part of production since 1996. Thanks to our many years of experience in the fields of vials, syringes, pipettes and bandages, among other items, our solutions are specially tailored to the exacting requirements of this industry and satisfy all the necessary regulations. Our range of services extends from consulting and planning to the implementation and qualification of the compliant overall system – including all the documents the regulations require.

Compliance Does Not Start with Validation

Regulatory requirements should not be added retrospectively. They already influence the selection of software, cameras, interfaces, user concepts and documentation structures.

OCTUM therefore considers regulatory requirements early in the project: when defining the inspection task, the system architecture, software configuration, data connectivity and later documentation.

This results in an inspection system that not only performs the technical inspection, but can also be integrated into regulated production and quality processes.

Key Functions for Regulated Environments

Audit Trail

An audit trail documents relevant changes and events within the system. This includes, for example, changes to inspection programs, user actions, parameter settings or system-relevant configurations.

This makes it traceable when a change was made and which user was responsible for it.

User and Permissions Management

Role and permission concepts define who is allowed to operate the system, configure it or modify inspection programs.

This allows responsibilities to be clearly assigned and helps prevent unintended or unauthorized changes.

Data Integrity

Inspection results, process data and system events must be stored completely, traceably and reliably.

OCTUM systems can be designed so that relevant inspection data can be clearly assigned to products, batches, formats or process information.

Electronic Records

In regulated production environments, electronic records can play a central role.

Inspection data, batch information, inspection results and system events can be documented and made available for later analyses or audits.

Recipe and Format Management

Inspection programs and formats must be managed in a structured way. Changes to recipes, parameters or inspection characteristics should be controlled and traceable.

This supports stable production when product formats, batches or inspection requirements change.

Interfaces and Data Connectivity

Inspection systems rarely operate in isolation. They often need to communicate with line control systems, the machine environment, MES, SCADA, ERP or customer-specific data systems.

OCTUM considers these interfaces during system planning so that inspection data can be transferred and processed in a technically meaningful way.

Qualification and Validation

Support for Qualification-Ready Implementation

Depending on project requirements, OCTUM supports the documented implementation of inspection systems for regulated production environments. This may include specifications, risk assessments, functional descriptions, test concepts and qualification-relevant documents.

Typical components of documentation may include:

  • User Requirement Specification
  • Functional Specification
  • Design Specification
  • Risk Analysis
  • Test and Acceptance Documentation
  • Support for IQ/OQ-Relevant Evidence
  • Description of Interfaces and Data Flows
  • Documentation of User and Permission Concepts

The specific scope of documentation is defined on a project-by-project basis and depends on the application, production environment and customer-specific requirements.

OCTUM Scope of Services

From the Inspection Task to Regulated System Integration

OCTUM does not develop inspection systems as isolated camera solutions, but as part of the production and quality process.

Technical, regulatory and organizational requirements are considered together:

  • Definition of the inspection task and inspection characteristics
  • Selection of suitable cameras, optics and lighting
  • Software configuration and inspection program logic
  • User and permission concept
  • Audit trail and format management
  • Data connectivity and interfaces
  • Rejection and feedback concepts
  • Documentation and qualification-relevant support
  • Integration into existing or new production lines

This results in inspection systems that effectively combine technical inspection, process integration and regulatory requirements.

Applications

Regulatory Requirements in Specific Inspection Applications

pharma.regulations is particularly relevant for inspection systems in regulated industries and demanding production environments.

Typical applications include:

vial.inspect - Inspection Systems for Vials

Automated inspection of vials before and after filling, including empty vials, vial mouth, stopper seat, crimp caps, print quality, human-readable text and codes.

ampoule.inspect - Inspection Systems for Ampoules

Automated inspection of ISO ampoules after sealing and cooling, including breakage, deformation, open ampoules and optical defects.

syringe.inspect - Inspection Systems for Syringes

Inline inspection of syringes and syringe components for completeness, position, assembly, printing, codes and quality-relevant characteristics.

pipette.inspect - Inspection Systems for Pipette Tips

Automated inspection of pipette tips, racks and packaging units for geometry, completeness, contamination and correct arrangement.

well.inspect - Inspection Systems for Wells and Trays

Automated quality inspection of wells, cups, microtiter plates and trays for geometry, surface, cleanliness, completeness and defects.

patch.inspect - Inspection Systems for Wound Care Products

Inline inspection of wound dressings, adhesive bandages and transdermal systems for contamination, surface quality, product position, active ingredient application, print quality and codes.

Frequently Asked Questions about Pharmaceutical Regulations and Inspection Systems

Which regulations are relevant for automated inspection systems in the pharmaceutical industry?

For automated inspection systems in regulated production environments, EU GMP Annex 11, EU GMP Annex 15, 21 CFR Part 11 and GAMP 5 are among the relevant requirements. The specific requirements depend on the application, production environment, data usage and the customer’s validation concept.

 

Is a machine vision inspection system a computerized system?

Yes. A machine vision inspection system typically consists of hardware, software, inspection programs, user management, data storage and interfaces. In GMP-regulated environments, it is therefore considered a computerized system.

 

What does 21 CFR Part 11 mean for inspection systems?

21 CFR Part 11 describes requirements for electronic records and electronic signatures. For inspection systems, this can make topics such as access control, audit trail, data integrity, electronic records and traceability relevant.

 

What role does EU GMP Annex 11 play?

EU GMP Annex 11 describes requirements for computerized systems in GMP-regulated environments. For inspection systems, this includes validation, risk management, user permissions, data integrity, audit trail, system operation and documentation.

 

What role does GAMP 5 play for inspection systems?

GAMP 5 supports a risk-based approach for GxP computerized systems. For inspection systems, this means that requirements, risks, system functions, verification and documentation are considered in a structured way and implemented on a project-specific basis.

 

Does OCTUM support validation?

OCTUM supports the validation-ready and qualification-relevant implementation of inspection systems. The specific scope depends on the project, application and customer validation concept.

 

Can inspection results be linked to batch or process data?

Yes. OCTUM inspection systems can be designed so that inspection results can be linked to product, format, batch or process data and made available for documentation, traceability or analysis.

 

Are OCTUM inspection systems suitable for audit trail and user management?

Yes. Depending on project requirements, OCTUM systems can be designed with user and permission management, audit trail, format management and documented change history.

Clarify Regulatory Requirements for Your Inspection System

Are you planning a machine vision inspection system for a regulated production environment?

OCTUM supports you with technical system design, integration into your production line and qualification-ready implementation – from the inspection task through to documentation.

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74360 Ilsfeld

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