EU Q&A on GDP Guidance

Drug Distribution

Hello, good people of the world! On March 28, 2014 the European Commission released a question and answer (Q&A) document related to their Good Distribution Practice (GDP) guidance. The original guidance is here. The Q&A document is here. Some highlights:

  1. Question: in Chapter 2 – Personnel, 2.5, does the statement “appropriate procedures relating to personnel hygiene, relevant to the activities being carried out, should be established and observed” refer to the health and/or cleanliness of the staff?Answer: It only refers to the cleanliness of the staff, so to avoid any alteration of the product.
  2. Question: in Chapter 3 – Premises and Equipment, 3.2.(3), is the intent of segregation to avoid “cross-contamination” as mentioned in chapter 5?Answer: The intent of this provision is to avoid handling errors and accidental swaps of products. This is why electronic segregation is allowed, except for falsified, expired, recalled and rejected products which always have to be segregated physically.
  3. Question: concerning Chapter 3 – Premises and Equipment, 3.2.1, how many probes are necessary to monitor the temperature?Answer: The number of probes and their placement depend on the risk analysis performed on the site and the placement should be in agreement with the mapping results.
  4. Question: Concerning Chapter 9 – Transportation, 9.2.(1), can we deviate from storage conditions if the manufacturer agrees to the transportation of the product within a certain temperature range (2°-25°c) for a limited time frame of 6 hours?Answer: No. Storage temperature limits as described by the manufacturer or on the outer packaging need to be respected for each stage of transport during the whole transport chain.

Any of these questions or answers leave you with more questions? Leave a comment below and please share this post with whomever you think would benefit.

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