| Literature DB >> 35385986 |
Nic Gillings1, Olaug Hjelstuen2, Martin Behe3, Clemens Decristoforo4, Philip H Elsinga5, Valentina Ferrari6, Oliver C Kiss7, Petra Kolenc8, Jacek Koziorowski9, Peter Laverman10, Thomas L Mindt11, Meltem Ocak12, Marianne Patt13, Sergio Todde14, Almut Walte15.
Abstract
This document is intended as a supplement to the EANM "Guidelines on current Good Radiopharmacy Practice (cGRPP)" issued by the Radiopharmacy Committee of the EANM (Gillings et al. in EJNMMI Radiopharm Chem. 6:8, 2021). The aim of the EANM Radiopharmacy Committee is to provide a document that describes how to manage risks associated with small-scale "in-house" preparation of radiopharmaceuticals, not intended for commercial purposes or distribution.Entities:
Keywords: Quality assurance; Radiopharmaceuticals; Risk assessment
Mesh:
Substances:
Year: 2022 PMID: 35385986 PMCID: PMC9308578 DOI: 10.1007/s00259-022-05738-4
Source DB: PubMed Journal: Eur J Nucl Med Mol Imaging ISSN: 1619-7070 Impact factor: 10.057
Fig. 1The key steps in QRM as described in ICH guideline Q9 on quality risk management [10]
| Severity (S) | Description | |
|---|---|---|
| Low | 1 | Expected to have little negative impact |
| Medium | 2 | Expected to have a medium negative impact |
| High | 3 | Expected to have a high negative impact |
| Occurrence (O) | Description | |
|---|---|---|
| Low | 1 | Failure expected to happen less than once per year |
| Medium | 2 | Failure expected to happen once per year |
| High | 3 | Failure expected to happen more than once per year |
| Detectability (D) | Description | |
|---|---|---|
| High | 1 | All failures are expected to be detected early enough |
| Medium | 2 | Some, but not all failures are expected to be detected early enough |
| Low | 3 | None of the failures are expected to be detected or are expected to be detected too late |
| Introduction |
| Annex 3 “Manufacture of Radiopharmaceuticals” outlines the requirements for manufacture of radiopharmaceuticals. Adherence to this annex is associated with the following premise (as stated in the annex): |
| Aim |
| The aim is to decide if and under which conditions it can be accepted to release the product before completion of all QC tests (here: test for sterility and radionuclidic purity) |
| Risk identification |
| The following hazards can occur, when the product is released before completion of the test for sterility and radionuclidic purity test: • Sepsis in the case of microbial contamination • Extra radiation dose due to radionuclidic impurities |
| Risk analysis |
| The risk of releasing radiopharmaceuticals before completion of all quality control tests is high as this could lead to a negative impact on the patient. This risk is mitigated by the fact that only small amounts of the product are administered to patients, all processes are validated, an adequate quality management system is in place and personnel involved in production, quality control and release of radiopharmaceuticals are appropriately trained in specific radiopharmaceutical aspects of the quality management system. All manufacturing steps take place in self-contained facilities dedicated to radiopharmaceuticals, accessible only by authorised personnel. Measures are established and implemented to prevent cross-contamination. Preventative maintenance, calibration and qualification programmes ensure that all facilities and equipment used in the manufacture of radiopharmaceutical are suitable and qualified. The facilities are routinely monitored so that the appropriate level of environmental cleanliness is maintained. The starting materials, packaging materials and critical process aids are purchased from approved suppliers. All documents related to the manufacture of radiopharmaceuticals are prepared, reviewed, approved and distributed according to written procedures. A written procedure detailing the assessment of production and analytical data is followed before the batch is released |
| Risk evaluation and control |
| With the adopted risk reducing activities, the risks are considered to be tolerable. All risks are accepted, on the condition that the described risk reducing activities are conducted |
| Introduction: |
| The precursor used for the preparation of PET radiopharmaceutical XXX is fully compliant with Ph. Eur. monograph 2902 except for the requirements for microbial contamination and bacterial endotoxins |
| Aim |
| The aim is to decide if and under which conditions the chemical precursor for a radiopharmaceutical preparation can be used, although there is no data on microbiological and endotoxin contamination |
| Risk identification: |
| The product may not be sterile and contain excessive levels of bacterial endotoxins |
| Risk analysis: |
| Severity: (3) |
| The risk of using a product that does not meet the sterility and endotoxin requirements is high as this could be detrimental to the patients health |
| Detectability: (1) |
| Controls and procedures are in place which will detect any microbial or endotoxin contamination of the precursor. A bioburden test of the radiopharmaceutical product (without terminal sterile filtration) is performed for every new batch of precursor as part of the incoming goods approval process. Endotoxin testing is performed on the radiopharmaceutical product before release |
| Occurrence: (1) |
| This failure is expected to happen less than once a year. The precursor is provided with a certificate of analysis which certifies the chemical purity which is specified at > 97%. YYY is a well trusted supplier and has been audited regularly and found to have a well-established quality management system. Each batch of product is sterile filtered, and each filter is tested for integrity after use. Each batch of product is tested for endotoxins prior to release |
| RPN = 3 × 1x1 = 3 Low, acceptable |
| Risk evaluation and control |
| The risk is considered acceptable with the installed reducing activities including at least a bioburden test of the product with every new batch of precursor and an endotoxin test of the radiopharmaceutical product before release |
| Process | Potential failure mode | Potential failure effects | Severity | Current controls | Occurrence | Detectability | RPN | Actions for the proposed plan, which complete the current controls |
| Label production | Labels contain incorrect information | Product incorrectly labelled | Medium (2) | Current label process to be used. The labels are double checked before approval for use and before use | Very low (1) | High (1) | 2 | New labels needed |
| Manufacturing | Production fails | Radiopharmaceutical batch is not ready for the patients | High (3) | Current validation policy will ensure that processes are validated | Very low (1) | High (1) | 3 | Validation of the new manufacturing process |
| QC | QC fails | Radiopharmaceutical batch may not be released | High (3) | Current validation policy will ensure reliability of the process. The analytical method will be validated. The equipment is already validated | Very low (1) | High (1) | 3 | Validation of new analytical methods |
| Release | Product is not released | Radiopharmaceutical is not available for the patients | High (3) | The process will be performed according to approved procedures, by trained operators | Very low (1) | High (1) | 3 | New procedures needed. Training to be performed |
Abbreviations
| EANM | European Association of Nuclear Medicine |
| cGRPP | Current Good Radiopharmacy Practice |
| QMS | Quality management system |
| SOP | Standard operating procedure |
| CAPA | Corrective actions and preventative actions |
| FMEA | Failure mode and effects analysis |
| ISO | International Organization for Standardization |
| OOS | Out of specification |
| OOT | Out of trend |
| Ph. Eur | European Pharmacopoeia |
| QC | Quality control |
| QRM | Quality risk management |
| RP | Radiopharmaceutical |
| RPN | Risk priority number |
Glossary
| Abnormal result | Results that are still within specification but are unexpected, unusual |
| Adverse trend | An identified trend that indicates a degradation in performance |
| CAPA | Corrective actions and preventative actions. A CAPA process is a formal way to implement appropriate corrective and preventative actions with the aim of eliminating causes of non-conformity such as deviations, OOTs, deficiencies from audits and other complaints. Prior to initiation of a CAPA process, non-conformities must be investigated systemically to determine the root cause. CAPA methodology should result in product and process improvements and enhanced product and process understanding |
| Change management | A systematic approach to proposing, evaluating, approving, implementing and reviewing changes that ensures that changes to methods, equipment and materials are properly documented and assessed before implementation |
| Corrective actions | Actions taken to eliminate the cause of a detected non-conformity to prevent recurrence |
| Detection | The process of identifying a failure mode |
| Deviation | A non-conformity with respect to approved procedures or established standards or specifications. A deviation can be planned or unplanned. A planned deviation is pre-approved and covers a specified period or number of batches |
| Failure mode | Different ways that a process or sub-process can fail to yield the anticipated result |
| Failure mode and effects analysis | The process of reviewing as many components, assemblies, and subsystems as possible to identify potential failure modes in a system and their causes and effects |
| Good radiopharmacy practice | Good radiopharmacy practice is described in the “Guidelines on current Good Radiopharmacy Practice (cGRPP)” by the Radiopharmacy Committee of the EANM [ |
| Occurrence | Probability that an event may happen within a given timeframe |
| Preventative actions | Actions taken to eliminate the cause of a potential non-conformity to prevent its occurrence |
| Product life cycle | All stages in the life of the product, from development through its clinical use |
| Quality risk management (QRM) | A systematic process for the assessment, control, communication, and review of risks to the quality of the pharmaceutical product throughout the product life cycle. Refer to Fig. |
| Risk | Combination of the occurrence and severity of a hazard (potential source of harm) or non-conformity |
| Risk assessment | Risk assessment is the initial step towards collecting information to support a risk decision. It consists of three main stages |
| Risk identification | The first stage of the risk assessment process, during which hazards are identified. All available information should be used systematically |
| Risk analysis | The second stage of the risk assessment process, during which the risk associated with the identified hazard or non-conformity is estimated |
| Risk evaluation | The third stage of the risk assessment process, during which the significance of the risk is determined by comparison of the answers provided during the risk identification and risk analysis stage with given risk criteria (e.g. quantitative scale or qualitative levels such as high, medium and low) |
| Risk control | This step follows the risk assessment, and the output is a decision regarding risk acceptance or reduction. Which risks can be accepted because of their low level, which risks can and need to be reduced/eliminated and which risks cannot be reduced but are accepted without reduction given an acceptable risk–benefit ratio |
| Risk reduction | Actions taken to decrease risk to a lower level. This can be achieved by reducing the occurrence or enhancing the detectability |
| Risk acceptance | An active decision to accept an identified risk |
| Risk communication | The act of sharing information and outcomes of a risk assessment |
| Risk review | Review or monitoring of output or results of a risk assessment considering (if appropriate) new knowledge and experience |
| Risk priority number (RPN) | A numeric, quantitative assignment of the level of risk associated with a process or steps in a process. Each failure mode is assigned a numeric score that quantifies the likelihood of occurrence, likelihood of detection and severity of impact. The product of these three scores is the RPN for that failure mode. RPN = severity rating × occurrence rating × detection rating |
| Root cause analysis | A systematic process for identifying root causes of problems conformities or other adverse events |
| Validation | The documented actions of confirming that any procedure, process, equipment, material, activity or system leads to the expected results |