National and international companies manufacturing pharmaceutical drugs,
vaccines and related products in Brazil are, of course, subject to inspection by
officials from ANVISA (Agência Nacional de Vigilância Sanitária, the National
Health Surveillance Agency). In recent years, ANVISA inspectors have, in
increasing scale, also been encountered outside of Brazil, focussing their
efforts on enterprises marketing pharmaceutical products in Brazil. Such
inspections are based on the Brazilian GMP guidelines the latest edition of
which was published as Resolution Anvisa RDC No 17 dated 16 April 2010 in
Portuguese [1]. Since then, an official English translation has also been
published by ANVISA [2].
Point of departure for GMP in Brazil
The newly elaborated Brazilian Federal Constitution of 1988 determined health
to be a public right for which government on all levels (federation, states, and
municipalities) is responsible. This was a novelty: earlier on, only persons
formally contracted by an employer plus their direct dependents as well as
pensioners with accumulated 30 years of formally contracted employment had
access to the public health system. Legislation established, in 1990, the
Sistema Único de Saúde (SUS) which can be translated as Single Health System. It
is one of the most extensive public health systems in the world: with SUS, the
entire Brazilian population - now passing the level of 200 million - obtained
access to the public health system, i.e. to medical treatment, health stations
and hospitals, laboratory services, blood centers, as well as to preventive
actions such as vaccination campaigns - all free of charge. A special system of
pharmacies was created in this context, the Farmácias Populares, serving
exclusively people with low income. They offer a basic selection of essential
medicines, with focus on generics, either free of charge or at low cost.
Presently, most drug stores in Brazil are affiliated to this system and operate
a specific sector for providing this service.
With the introduction of SUS, the Brazilian government became the biggest
purchaser of medicines in the country. In order to assure security, efficiency
and quality of the medicines sold through the SUS system as well as through all
the other pharmacies, the implementation of GMP principles became inevitable.
Introducing GMP had a most welcome side effect: all suppliers were required to
meet uniform quality standards with the consequence that a fair point of
departure for competition between suppliers was established; price reductions
resulted as a consequence.
Introducing GMP to Brazil
Brazil is a member of the World Health Organization (WHO). As such, it is
obliged to incorporate the WHO pharmaceutical quality assurance guidance into
its national health legislation system without major deviations. The first
Brazilian GMP guideline was published in 1995. The present edition, RDC no.
17/2010, is derived from the 2003 edition of the basic WHO GMP guide: Main
principles for pharmaceutical products - Quality management in the drug
industry: philosophy and essential elements. Some segments of RDC 17/2010,
however, are based upon more recent WHO guidances, or upon guidance from other
regulatory bodies.
One important peculiarity deserves mention: Whereas WHO uses the term
"should" for the individual determinations, in agreement with the general
practice in the standardization and guidelines literature, the ANVISA guidelines
give preference to "must" determinations.
GMP guidelines on related topics have also been published by ANVISA, e.g. for
active pharmaceutical ingredients and for the preparation of individual
prescriptions in healthcare pharmacies.
In the following, only determinations differing from those in the WHO GMP
guideline are addressed. This compilation is not complete but only focuses on a
few topics. For more detailed information please find a comprehensive version of
the article along with the Brazilian GMPs in our next Update for the GMP
MANUAL.
A brief summary
Title I: Initial provisions
This chapter defines the scope and purpose of RDC 17/2010. Minimum GMP
requirements are established regarding manufacturing medicinal products in
Brazil and outside the country for the local market. Methods not addressed in
BPC 17/2010 resulting from technical progress or the specific requirements of
given products are permitted to be adopted, provided they are validated and do
not prejudice the quality of the product. Medicinal products are subject to
registration and may be produced only by manufacturers duly licensed and
authorized; these companies are regularly inspected by the responsible national
authorities. Occupational health topics and environmental safety are, as a rule,
not addressed; however, manufacturers must guarantee worker safety and take the
necessary steps for environmental protection.
Title II: Quality management
This Title follows closely the corresponding general WHO GMP guideline: the
structure and its subdivision into a total of 17 chapters are identical.
Regarding the subject matter presented in each chapter, it is, however,
structured differently. The Brazilian guideline is written in the style of the
legal document which it is: each Article focusses on a single determination
which can be numerically referred to in inspection reports and subsequently
enforced if required.
One difference is regarding the "technically responsible person". This
function is required by law for all industrial companies operating in Brazil.
Its range of responsibilities goes beyond that of the "authorized person" in the
WHO and the "qualified person" in the EU GMP guidance. Title II requires
complaints regarding falsified products and stolen cargo to be notified to the
responsible health authorities. Starting and intermediate materials out of
specification must be investigated and actions according to the CAPA procedure
must be taken.
Title III: Sterile products
This Title follows very closely the corresponding WHO determinations
published in 2002. WHO has since substituted them with a new edition published
in 2010. Two topics (isolator technology, blow/fill/seal technology) have been
added in RDC 17/2010 to the original WHO text. These have been reproduced,
without any change, from the 2008 edition of Annex 1 to the EU GMP guide.
Regarding terminally sterilized products, RDC 17/2010 is stricter than WHO:
high risk operations must be performed in grade C conditions. Garments of
persons working in grade A/B areas must be changed after each work session.
Contrary to WHO, no exceptions are foreseen.
Title VII: Computer information systems
The original EU GMP guidance established in Annex 11 has served as base for
this Title. The concepts of risk management and electronic signatures are not
addressed. For the validation of computerized systems, an exhaustive guide has
been prepared by ANVISA in co-operation with professionals from the Brazilian
Chapter of ISPE - the International Society of Pharmaceutical Engineers.
Title VIII: Herbal medicines
This Title is based upon the corresponding WHO guidance published in 2006 and
presently in force. Determinations are established for herbal medicines only,
combination products with those of animal or mineral origin are not addressed.
An appropriate quality assurance system must be in place, prime materials
require adequate control, and processes as well as methodologies must be
validated. Herbal raw material derivatives containing genetically modified
organisms must comply with the specific standards in force.
Conclusion
The Brazilian GMP guideline RDC 17/2010 for medicinal products comprises not
only the generally applicable GMP stipulations, but also covers a number of
additional topics such as sterile, biological and herbal products, water for
pharmaceutical use as well as qualification and validation. Based upon
corresponding WHO GMP guidance which, on its part, is compatible with EU GMP
guidelines, it offers sound GMP guidance without surprises.
References
[1] Ministério de Saúde, Agência Nacional de Vigilância Sanitária ANVISA,
Resolução RDC No 17, de 16 de abril de 2010: Boas Práticas de Fabricação de
medicamentos (Ministry of Health, National Health Surveillance Agency,
Resolution RDC No 17 of 16.04.2010: Good practices of manufacturing medicinal
products).
[2] ANVISA Resolution RDC No 17 of 16.04.10: Good practices of medicament
manufacturing (offizielle englischsprachige Ausgabe).
web source:
http://www.gmp-publishing.com/en/lead-article/gmp-aktuell/gmp-logfile-12-2013-brazilian-gmp-guidelines.html
Author:
Dr. Hans H. Schicht
Contamination Control Consulting
Langwisstrasse 5
8126 Zumikon
Switzerland