Int J Pharm Pharm Sci, Vol 16, Issue 5, 7-15Review Article

PHARMACEUTICAL AUDIT PROCESS, OUTCOMES, AND IMPLICATIONS–OVERVIEW

KRUTHIKA R. K.¹, SANGITA MISHRA1, ARJUN M.1, M. P. VENKATESH²*

¹Department of Pharmaceutics, JSS College of Pharmacy, JSS Academy of Higher Education and Research, Sri Shivarathreeshwara Nagar, Mysuru-570015, Karnataka, India. 2Department of Pharmaceutics, JSS College of Pharmacy, JSS Academy of Higher Education and Research, Sri Shivarathreeshwara Nagar, Mysuru-570015, Karnataka, India, and Guest Assistant Professor, Faculty of Pharmaceutical Sciences, UCSI University, Malaysia
*Corresponding author: M. P. Venkatesh; *Email: venkateshmpv@jssuni.edu.in

Received: 31 Aug 2024, Revised and Accepted: 09 Mar 2024


ABSTRAC

The audit process is a crucial component of regulatory compliance and quality assurance in both the United States of America (USA) and the European Union (EU). This review paper compares and analyses the audit processes, results, and ramifications in these two important markets.

The study investigates how pharmaceutical audits affect patients’ trust, market stability, and profitability of a company while highlighting the need for adherence to quality standards. Data integrity, supply chain complexity, and adherence to exacting quality standards are just a few of the notable difficulties faced by auditors in the USA and EU. There is a need to have a strong pharmacovigilance system as well to guarantee the security and effectiveness of pharmaceutical products for patients.

This study can be useful reference material for stakeholders, decision-makers, and companies looking to increase accountability, reduce risks, and uphold the integrity of a firm’s operations in the global market. A thorough analysis of audit procedures in the USA and EU will facilitate in promotion of effective and efficient manufacturing, control, and distribution of pharmaceutical products while boosting confidence among patients and in the healthcare system as a whole.

Keywords: Pharmaceutical audit, Process, Outcomes, Implications, Audit regulations, GMP audit


INTRODUCTION

A dynamic aspect of every pharmaceutical company is auditing. The goal of a carefully conducted audit is to ensure that all quality assurance and quality control (QC) efforts are of the highest quality possible. One approach to assessing a pharmaceutical manufacturing program is to ensure that its policies adhere to Good Manufacturing Practice (GMP) and regulatory standards [1]. External specialists or a team chosen by the management of pharmaceutical corporations typically conduct quality audits. The results of an audit will assist in improving the process and establishing a better system for the benefit of the organization. An audit will evaluate the strengths and weaknesses of quality assurance methods [2]. Pharmaceutical audits cover procedures for performance qualification up to design qualification. Standard Operating Procedure (SOP), guidelines, and validation policies were also provided [3].

By automating audit-related operations, including document routing, data collecting, notifications, approvals, and activity escalation, the Simpler Quality Management System (QMS) audit management software system may considerably minimize the time and effort required to pass audits. The audit procedure involves careful preparation, careful document review, physical inspection of facilities, and interviews with staff at all levels [4]. The purpose is to evaluate the organization's compliance with Good Distribution Practices (GDP) and GMP, which protect the correct handling and distribution of medicines and ensure safe, dependable, and effective drug manufacture. Auditors meticulously document all findings and observations made throughout the audit, including any deviations, instances of non-compliance, or possible hazards. These observations form the basis for the implementation of Corrective and Preventive Actions (CAPA), which aim to address identified problems and reduce possible new ones [5].

The FDA and EMA are only two of the regulatory organizations that provide recommendations that need to be followed by pharmaceutical quality auditors. Companies may improve their entire QMS by identifying inefficiencies, streamlining procedures, and putting best practices into exercise via regular audits. In the end, these audits play a crucial role in preserving high standards for product quality, boosting consumer trust, ensuring patient safety, and preserving the pharmaceutical company's image in the competitive market [6]. Pharmaceutical firms show their commitment to providing consumers with safe and dependable pharmaceutical goods by following strict quality audit methods [7].

To rigorously assess and confirm pharmaceutical companies' compliance with strict GMP, robust pharmacovigilance procedures, and stringent data integrity standards, the FDA conducts thorough and systematic pharmaceutical audits. By conducting these thorough audits, the FDA makes sure that pharmaceutical products adhere to the highest standards of quality, safety, and efficacy. This ensures the protection of public health and fosters unwavering confidence in the pharmaceutical industry's morality intention, and commitment to patients' health and welfare. In these audits, the FDA's stringent monitoring and dedication to regulatory excellence are crucial in maintaining the highest standard of patient safety and encouraging ongoing research and development in the pharmaceutical industry [8, 9].

In the EU, EMA uses pharmaceutical audits to carefully evaluate adherence to GMP, GDP, and pharmacovigilance procedures. These audits are essential for assuring pharmaceutical goods' quality, safety, and efficacy. These also protect the public's health and increase patients' and customers' confidence in the pharmaceutical business. EU pharmaceutical audits work to reduce risks, stop the sale of fake medications, and promote an atmosphere of quality and accountability in the industry by ensuring adherence to strict standards and conducting ongoing surveillance to identify areas of improvement [9].

Methods and search criteria

The research carefully considers the activities of important agencies like the European Medicines Agency (EMA) and the Food and Drug Administration (FDA) in examining the regulatory frameworks controlling pharmaceutical audits in the USA and EU. It also examines the underlying ideas of the standards, formats, and audit methods in the USA and EU. This paper utilizes guidelines (FDA/EMA) and existing literature on the subject published after 2005 to create a comprehensive representation of pharmaceutical audits. Keywords used to search relevant literature and guidelines are “Pharmaceutical Audit”, “GMP Guidelines”, “cGMP guidelines”, “EMA Audit Regulations”, “FDA Audit Regulations”, “Pharmaceutical Audit Planning”, “Corrective Action Preventive Action”, “Pharmaceutical Quality Control”.

DISCUSSION

Audits in the United States

Pharmaceutical audits are an essential aspect of the regulatory supervision process in the US, requiring pharmaceutical firms to adhere to GMP and other pertinent global and local laws. These audits, which are largely carried out by the FDA, are intended to maintain the efficacy, quality, and safety of pharmaceuticals and other medical items sold on the American market [10].

Audits in the european union

Pharmaceutical audits are crucial parts of the regulatory framework in the EU to guarantee the safety, effectiveness, and quality of pharmaceutical goods. These audits, which are usually carried out by regulatory agencies, are intended to evaluate whether GMP and GDP standards and guidelines are being followed [18].

Key aspects of a pharmaceutical audit in the EU are: -

The audit process

The flow of the audit process is depicted in fig. 1.

Constituents of the efficient audit process

Communication throughout the audit is crucial for knowing and being informed about the organization being audited. To promote transparency, enable compliance assessment, and address any issues or concerns, a seamless flow of information between auditor and auditee is required. This exchange of information generates a positive, cooperative atmosphere that enhances understanding of business practices and encourages the general improvement of quality and compliance [26].

Auditors can successfully prepare for the audit by requesting a wide range of data from the audited organization. This data offers a thorough picture of the business's operations, procedures, and compliance practices, allowing auditors to concentrate on the right areas throughout the audit and assuring a more focused and effective evaluation.

Typically, the following topics are covered:

The findings should be properly documented and identify opportunities for improvements, non-conformance to procedures, deviations, and recommendations. Based on this, the auditee needs to create CAPA, perform root cause analysis, track changes to ensure conformance, and update actions taken to implement the recommendations [32, 33]

Fig. 1: High-level flow of the audit process [55]

Importance of auditing in US and EU markets

In the US and EU markets, CMC auditing is extremely important and serves several vital purposes, including the following;

Audit process flow-chart

The Process of audit is depicted in fig. 2.

Fig. 2: Typical audit flow [56]

Understanding audit outcomes and their implications

Audits are essential in the pharmaceutical sector for assuring adherence to several regulatory obligations and industry standards. These audits may be undertaken by independent third-party auditors, regulatory bodies, or both internal and external auditors. Assessments of the quality, safety, and compliance of pharmaceutical goods and procedures are made in the audit results and reports for the pharmaceutical industry. The following are some significant characteristics of audit findings and reports in the pharmaceutical sector:

Audit reports in pharma

Pharmaceutical audit reports share similarities with general audit reports but are tailored to address industry-specific concerns. These reports typically include:

Pharmaceutical audit reports are important records because they offer insightful information about the organization's quality and compliance procedures, assisting in ensuring the safety and effectiveness of pharmaceutical goods on the market. If major non-compliances are found, regulatory authorities may utilize these reports to determine a company's capacity to maintain compliance and may take additional steps based on the audit results, such as issuing warning letters or enforcing their findings.

Audit implications

Implications of an audit include both positive and negative outcomes. They may consist of:

The audit consequences will change based on the audit's conditions. These are some of the most typical audit implications, nevertheless. Here are some additional examples of audit implications:

Overall, there may be both good and negative audit effects. The precise ramifications will change based on the audit's conditions. Before conducting an audit, it is crucial to be informed of any potential repercussions [42].

Common pharmaceutical audit challenges

Strategies to overcome the audit challenges in the pharmaceutical industry

Pharmaceutical audit issues must be overcome through careful preparation, close attention to detail, and a dedication to regulatory compliance. Here are some tactics to use when tackling typical problems:

Guidelines for GMP audit in the pharmaceutical industry

The FDA has established cGMP guidelines, which are used as a standard for evaluating the quality of pharmaceutical goods to make sure they meet the required parameters. These rules attempt to guarantee that a drug's potency corresponds to its claims for the product's safety. The main goal of cGMPs is to equip makers of pharmaceutical goods with guidelines for comprehensive QC. The FDA inspects and evaluates the manufacturer's capacity to produce human and veterinary pharmaceuticals and the machinery being utilized to determine compliance. Manufacturers must adhere to current requirements. The practice must meet these standards' requirements for both "good" and "current" practice. The manufacturer's controls, tools, and procedures must be up to date. Current can be taken to mean what is typically accepted in the field. Therefore, the manufacturer is required to follow the new processes if new standards are created that are superior to the present ones [47].

GMP audit plan

GMP audit plan typically consists of the following components as shown in fig. 3.

Fig. 3: GMP audit plan [48]

Difference between US and EU audit regulation

Refer table 1.

Corrective actions and follow-up after the audit

The adoption of remedial steps once an audit is finished is crucial for dealing with any breaches or issues found during the inspection. Correcting systemic defects is a priority since it assures the avoidance of repeat occurrences and promotes a culture of improvement within the organization. By optimizing processes through these corrective measures, the company increases its chances of becoming certified, which would signify compliance with industry norms and enhance the company’s credibility in the market.

Remedial action is a four-step procedure that includes cautious planning, painstaking implementation, watchful monitoring, and thorough review. The firm acquires a methodical way2edtff to recognize, address, and assess the success of the implemented corrective actions through these sequential processes. The company's continued adherence to rules is ensured by this cycle of continuous improvement, which also boosts overall operational effectiveness and fortifies the company's position within the sector [50].

Corrective measures can assist a business in streamlining its procedures and winning certification. Here are some phases in the process of remedial action. Refer to 4.

A corrective action plan is a piece of writing used in quality management that describes a series of actions taken to rectify problems and gaps in organizational procedures.

To address any non-conformances found during the audit, the auditee is responsible for completing the corrective action plan (CAP). A CAP is a technique for recording non-compliance problems, pinpointing their underlying causes, and collecting quantifiable, doable fixes and reasonable dates. After a certain amount of time, it's critical to gauge and evaluate the corrective action's efficacy. A corrective action plan must be meticulously documented and closely monitored to remain on track. The CAP procedure is depicted in fig. 4.

Table 1: United States and European Union Audit Regulations

Aspect US audit regulations EU audit regulations References
Structure The FDA is a centralized organization that manages the process of promoting drug manufacturing and approval in the USA. EMA is the centralized scientific evaluation body for therapeutics in the EU. It is governed by European Commission guidelines. [48, 49]
Approval process Preclinical research, Phase I, II, and III clinical trials, as well as a review procedure for New Drug Applications (NDAs), are all components of the FDA's multi-phase approval process for medications. Similar procedures are used by the EMA for non-clinical testing, clinical trials (Phase I, II, and III), and the examination of marketing authorization applications (MAAs). [48, 49]
Audit procedures FDA refers to audits as internal audits. Additionally, the FDA examines its operations to make sure regulations are being followed. EMA refers to audits as self-inspections. The Mutual Recognition Agreement (MRA) between the EU and the US enables reliance on one another's human medicine inspections inside their respective national borders. [48, 49]
Audit trail discussion FDA 21 CFR 11–Use of secure computer-generated time-stamped audit trails to independently record the date and time of operator entries and actions that create, modify, or delete electronic records EU GMP Annex 11–Consideration should be given, based on a risk assessment, to building into the system the creation of a record of all GMP-Relevant changes and deletions (a system-generated audit trial) [48, 49]
Jurisdiction and authority The FDA employs people to keep an eye on drug assessment requests and the development of new drugs. The ultimate regulatory decision is made by the European Commission (EC), and the EMA is not permitted to authorize or approve certain drugs. [48, 49]
Drug approval process

The FDA is a centralized organization that manages the process of creating drugs in one nation.

The FDA's personnel keeps an eye on drug review applications and the medication development process.

Many European countries have a reviewing authority called EMA that oversees the procedure.

The national agencies of the member states evaluate the EMA.

[48, 49]

 

Fig. 4: Corrective action plan procedure [51]

Accepting the risk underlying the audit finding and its impact on eliminating or revising the offending control activity to the extent that compensating controls are in place to address the core risk(s) are the only two ways to resolve the audit finding if a company opts not to implement a CAP. However, the most efficient method to address an audit finding is to put a corrective action plan into place [51].

Follow-up after the audit

The audit process includes follow-up to make sure corrective measures have been taken and are working properly following an audit. To confirm that management action plans have been completed, follow-up audits are performed. The follow-up procedure entails keeping track of how management-communicated outcomes are handled. The steps in the follow-up procedure are listed below.

The implementation and ongoing monitoring of audit findings and their mitigation are greatly aided by the follow-up log used in internal auditing. It's crucial to share the follow-up log activities in fresh audit reports or by distributing an updated version of the relevant audit report that includes the new follow-up log activity. If areas suggested for improvement are not implemented by management, the internal audit's work fails to improve the internal control, risk, and governance frameworks and hence needs to be addressed. Audit committees and senior management need confirmation that controls are more effectively managing risk and that agreed-upon actions in internal audit reports have been executed appropriately and within the originally provided timeframes [54].

To verify that corrective measures have been implemented and are working, follow-up is crucial following an audit. The follow-up procedure entails tracking how outcomes conveyed to management are handled and confirming that track action plans have been completed. Internal auditing's follow-up log is crucial to the implementation, ongoing evaluation, and mitigation of audit findings. It is crucial to convey the follow-up log activities in fresh audit reports or by distributing an updated version of the relevant audit report that includes the new follow-up log activity.

CONCLUSION

Audits in the US and EU are crucial for maintaining integrity in manufacturing and research, ensuring regulatory compliance, and fostering public trust in healthcare. The contrast in regulatory frameworks underscores the need for stringent regulations to uphold independence and ethics in auditing. Businesses and auditors must adapt to changing criteria for optimal effectiveness, especially in dynamic regulatory environments affecting pharmaceutical operations. Auditors must identify the complexities of the pharmaceutical sector and stay updated on medical research, drug development, and regulations to ensure the relevance of their methodology. An effective audit process is essential for protecting public health, and financial integrity and fostering sustainable growth in healthcare. Emphasizing the importance of audits reinforces moral standards, ensures patient safety, and supports a robust healthcare system.

ACKNOWLEDGEMENT

The Authors express sincere gratitude to JSS Academy of Higher Education and Research and JSS College of Pharmacy, Mysuru for their support in carrying out their work.

FUNDING

No grant or funding was received or requested for this work

AUTHORS CONTRIBUTIONS

KR played a comprehensive role by conceptualizing and designing the study and was involved in literature search, data acquisition and analysis, statistical analysis, manuscript preparation, editing, and review. SM supported in study design and was actively involved in content preparation, data synthesis, manuscript preparation, editing, and review of the same. AM contributed to manuscript preparation, editing, and review. MP helped in the study conceptualization and review of the manuscript.

CONFLICTS OF INTERESTS

The authors declare no conflict of interest.

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