The U.S. Food and Drug Administration (FDA) recently released a draft guidance document titled “Quality Agreements for Contract Manufacturing Organizations” to provide direction to pharmaceutical companies on establishing quality agreements with their contract manufacturers.
The FDA defines a quality agreement as “a comprehensive written agreement between parties involved in the contract manufacturing of drugs that defines and establishes the manufacturing activities of the parties and the responsibilities of each.” The purpose of these agreements is to ensure that the contract manufacturer is producing drug products that meet the quality standards established by the pharmaceutical company.
The FDA has long emphasized the importance of quality agreements in drug manufacturing, and this guidance document seeks to provide additional clarity on the expectations for such agreements. The guidance covers a range of topics, including the scope of the agreement, quality requirements and responsibilities, change control procedures, and dispute resolution.
One key aspect of the guidance is the emphasis on communication between the pharmaceutical company and the contract manufacturer. The guidance stresses the need for ongoing communication to ensure that both parties are aware of any changes that may affect the quality of the drug product. This includes changes in manufacturing processes, equipment, or personnel.
The guidance also addresses the issue of quality oversight. The pharmaceutical company is ultimately responsible for ensuring the quality of the drug product, and the guidance underscores the need for appropriate oversight of contract manufacturing activities. This may include regular site visits and audits to assess the contract manufacturer`s compliance with quality standards.
Another important aspect of the guidance is the inclusion of specific requirements for quality agreements related to combination products. Combination products, which are products that combine drugs, medical devices, or biologics, can pose unique challenges in terms of quality oversight. The guidance provides guidance on how to address these challenges through the use of quality agreements.
Overall, the FDA`s draft guidance on quality agreements for contract manufacturing organizations provides valuable direction to pharmaceutical companies on how to establish effective quality agreements with their contract manufacturers. By emphasizing the importance of communication, quality oversight, and clear responsibilities, the guidance can help ensure the quality and safety of drug products for consumers. As the guidance is in draft form, it is subject to change before finalization.