Guidance on release for supply
For medicines manufacturers
Version 1.0, June 2013
Therapeutic Goods Administration
Guidance on release for supply for medicines
manufacturers
Page 2 of 16
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About the Therapeutic Goods Administration (TGA)
· The Therapeutic Goods Administration (TGA) is part of the Australian Government
Department of Health and Ageing, and is responsible for regulating medicines and
medical devices.
· The TGA administers the Therapeutic Goods Act 1989 (the Act), applying a risk
management approach designed to ensure therapeutic goods supplied in Australia
meet acceptable standards of quality, safety and efficacy (performance), when
necessary.
· The work of the TGA is based on applying scientific and clinical expertise to decision-
making, to ensure that the benefits to consumers outweigh any risks associated with
the use of medicines and medical devices.
· The TGA relies on the public, healthcare professionals and industry to report problems
with medicines or medical devices. TGA investigates reports received by it to
determine any necessary regulatory action.
· To report a problem with a medicine or medical device, please see the information on
the TGA website <
http://www.tga.gov.au>.
Copyright
© Commonwealth of Australia 2013
This work is copyright. You may reproduce the whole or part of this work in unaltered form for your own personal
use or, if you are part of an organisation, for internal use within your organisation, but only if you or your
organisation do not use the reproduction for any commercial purpose and retain this copyright notice and all
disclaimer notices as part of that reproduction. Apart from rights to use as permitted by the Copyright Act 1968 or
allowed by this copyright notice, all other rights are reserved and you are not allowed to reproduce the whole or any
part of this work in any way (electronic or otherwise) without first being given specific written permission from the
Commonwealth to do so. Requests and inquiries concerning reproduction and rights are to be sent to the TGA
Copyright Officer, Therapeutic Goods Administration, PO Box 100, Woden ACT 2606 or emailed to
<
Confidentiality
All submissions received will be placed on the TGA’s Internet site, unless marked confidential. Any confidential
material contained within your submission should be provided under a separate cover and clearly marked “IN
CONFIDENCE”. Reasons for a claim to confidentiality must be included in the space provided on the TGA submission
coversheet. For submission made by individuals, all personal details, other than your name, will be removed from
your submission before it is published on the TGA’s Internet site. In addition, a list of parties making submissions will
be published. If you do not wish to be identified with your submission you must specifically request this in the space
provided on the submission coversheet.
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Version history
Version Description of change Author Effective date
V1.0
Original publication
Office of Manufacturing
Quality
03/06/2013
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manufacturers
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Contents
About this guidance 5
Part 1: General requirements and responsibilities 6
1. Introduction ________________________________________________________________ 6
2. Duties of an Authorised Person (AP) ___________________________________ 8
3. Manufacture in different locations _____________________________________ 9
4. Release for supply at manufacturing sites outside Australia _____ 10
5. Responsibilities of the AP in relation to product quality review
(PQR) __________________________________________________________________________ 11
6. Responsibilities of the AP in relation to on-going stability testing11
Part 2: Specific considerations for specific areas of
manufacture 13
Glossary 14
List of acronyms used 15
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About this guidance
This guidance document is published by the TGA to provide industry with guidance on
release for supply of medicines. This guidance document is developed in consultation with
industry involving experts from the relevant industry associations.
Industry has indicated the need for TGA guidance on release for supply, for various
reasons.
· The Australian system of release for supply by an Authorised Person is different from
the European system of batch release by a Qualified Person. Consequently, Annex 16 of
the current PIC/S Guide to Good Manufacturing Practice for Medicinal Products has
not been adopted in Australia, leaving industry with an information gap that could be
filled with a guidance document specific for the Australian situation with regards to
release for supply of medicinal products.
· With the adoption of the PIC/S Guide to Good Manufacturing Practice for Medicinal
Products – 15 January 2009 - PE009-8, the requirement to prepare regular Product
Quality Reviews (clause 1.4) was newly introduced and further detail was provided on
several pre-existing requirements, for example those on the on-going stability
program. As these responsibilities are related to the Authorised Person’s
responsibility for release for supply, additional guidance was required on how to meet
these responsibilities, in particular for complex manufacturing and supply chain
situations.
In order to provide a comprehensive overview on release for supply, this document
contains two parts.
· Part 1 describes the general requirements and responsibilities regarding release for
supply by an Authorised Person applicable to all TGA licensed and/or certified
manufacturers and to Australian sponsors.
· Part 2 specifies specific considerations on how the general requirements described in
Part 1 above can be met for specific areas of manufacture, for example complementary
medicines or sunscreens, or for different supply chains.
This guidance document may also be applied to investigational medicinal products,
subject to any difference in the legal provisions and more specific guidance in Annex 13 of
the current PIC/S Guide to GMP.
This guidance document does not apply to products covered under the regulatory
framework for biologicals (products covered in Part 3-2A of the Therapeutic Goods Act
1989 such as products containing or derived from human cells or human plasma. However
this guidance does apply to medicines from biological origin, such as vaccines and
biotechnology products.
This guidance document does not address the official control authority batch release
specified for certain blood and immunological products.
Nothing in this guidance document should be taken as overriding the arrangements of a
medicine’s Marketing Authorisation.
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Part 1: General requirements
and responsibilities
1. Introduction
1.1 The PIC/S Guide to Good Manufacturing Practice for Medicinal Products (PIC/S Guide
to GMP), clause 1.1vii defines release for supply as: “certification by an Authorised Person
that each production batch has been produced and controlled in accordance with the
requirements of the marketing authorisation and any other regulations relevant to the
production, control and release of medicinal products”.
Apart from clause 1.1vii, requirements relating to release for supply are also specified in
other clauses of the PIC/S Guide to GMP, for example in clauses 1.2, 1.3vii and 2.3.
1.2 Release for supply is considered a step in medicines manufacture, as it is specifically
mentioned in the definition of manufacture in chapter 1, section 3 of the Therapeutic Goods
Act 1989 (the Act), which reads:
manufacture, in relation to therapeutic goods that are not medical devices, means:
a. to produce the goods; or
b. to engage in any part of the process of producing the goods or of bringing the
goods to their final state, including engaging in the processing, assembling,
packaging, labelling, storage, sterilising, testing or releasing for supply of the
goods or of any component or ingredient of the goods as part of that process.
1.3 Each batch of finished medicinal product must be released for supply by an Authorised
Person (AP) before being sold or supplied in Australia or exported from Australia. This
applies to registrable and listable medicines in the same manner, as well as to
investigational medicinal products (phase 2 or later) that are not required to be entered in
the Australian Register of Therapeutic Goods (ARTG).
1.4 The AP is authorised by the manufacturer through a statement in the manufacturer’s
quality management system. The manufacturer takes responsibility to ensure the AP’s
level of education and expertise using the training arrangements in the manufacturer’s
quality management system. This is verified by the TGA during inspections.
1.5 Production, control and release of medicines in Australia are regulated in the Act and
the Therapeutic Goods Regulations 1990 (the Regulations). Consequently, release for
supply to the Australian market specifically involves a verification of all production and QC
testing records of a batch, for compliance with Chapters 2 and 3 of the Act. This
verification should focus on compliance with the following authorisations and standards.
a. All aspects of the Marketing Authorisation. The Marketing Authorisation includes
all details in the Australian Register of Therapeutic Goods (ARTG), as well as all
other matters in relation to the Marketing Authorisation agreed in writing
between the TGA and the Australian sponsor.
b. For domestic manufacturers: the licence to manufacture therapeutic goods,
including the authorisations and conditions under the licence; the steps in
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manufacture granted under section 38 of the Act as well as standard conditions
of licences as imposed under section 40 of the Act.
c. For overseas manufacturers: the TGA GMP certificate and/or GMP clearance(s),
specifically their authorisations and conditions, as imposed under sections
25(1)(g), 26(1)(g) and 26A(3) of the Act.
d. The Code of Good Manufacturing Practice (GMP) as specified in the current
Manufacturing Principles.
e. Default standards under Section 10 of the Act, including the British
Pharmacopoeia (BP), European Pharmacopoeia (EP) and United States
Pharmacopoeia (USP).
f. All applicable Therapeutic Goods Orders (TGOs).
Guidance documents available on the TGA web site provide information for specific
groups of medicines on how these requirements can be complied with.
In order to effectively take responsibility for release for supply of a finished product batch,
an AP should have full access and detailed knowledge and understanding of each of the
above.
1.6 “Release for supply” is the preferred term as this term reflects the legal obligations
under the Act. In addition, “release for supply” or “release” are internationally harmonised
terminology. The term ‘release for sale” has become obsolete since the requirement to
release finished product batches also applies to medicines that are not intended to be sold,
for example free samples and investigational medicines. In the context of this guidance
document, release for supply is defined to be one of the following types.
a. Release of a finished product batch for supply to the Australian market
b. Release of an Active Pharmaceutical Ingredient (API) or an intermediate or bulk
product for further processing to the next manufacturer in the manufacturing
supply chain
c. Release of a Phase 2 or later investigational medicinal product for use in human
clinical studies
d. Release for export.
Release for supply should not be confused with internal release steps within a
manufacturing organisation. These internal releases within the same quality system are
not required to be performed by an AP, provided the finished product is released for
supply by an AP.
1.7 As release for supply is a licensable step in manufacture within Australia, an Australian
sponsor who is reluctant to share the relevant information in the Marketing Authorisation
with a (contract) manufacturer performing release for supply, for example due to
confidentiality issues, has the following options available to them.
a. Implement a confidentiality agreement (or include confidentiality statements in
the GMP agreement).
b. Contract out the release for supply to another manufacturer with which there are
no confidentiality concerns provided that manufacturer holds the relevant
licence or current GMP certification/GMP clearance(s).
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c. Seek to obtain a TGA licence to manufacture therapeutic goods covering release
for supply.
Contracting out release for supply to an independent AP is only allowed if the AP holds or
works under a TGA licence or a current GMP clearance that includes release for supply.
1.8 It is the responsibility of the sponsor to ensure that each ARTG entry includes at least
one TGA approved (= licensed or holding a current GMP clearance) manufacturer that is
responsible for release for supply.
2. Duties of an Authorised Person (AP)
2.1 Before releasing a batch for supply, the AP should ensure, with reference to the
guidance above, that at least the following requirements have been met.
a. The batch has been produced and controlled in accordance with the
requirements of the Marketing Authorisation1.
b. The batch has been produced and controlled in accordance with the Code of GMP
as defined in the Manufacturing Principles (for domestic sites) or, in the case of a
batch manufactured in an overseas country, in accordance with good
manufacturing practice standards at least equivalent to that Code of GMP.
c. All manufacturers involved in producing the batch:
i. hold a TGA licence or a current GMP clearance for all of the manufacturing
steps they have performed
ii. are included in the ARTG entry for the manufacturing steps performed.
d. The principal manufacturing and release testing processes (as per finished
product specifications) have been validated; account has been taken of the actual
production conditions, manufacturing and test records.
e. All the necessary checks and tests have been performed; including any additional
sampling, inspection, tests or checks initiated because of deviations or planned
changes.
f. All necessary production and quality control documentation has been completed
and endorsed by the staff authorised to do so. For quality control documentation
this includes out of specification (OOS) investigations.
g. Any significant deviations or planned changes in production or quality control
have been authorised by the persons responsible in accordance with a defined
system. Any changes requiring variation to the Marketing Authorisation or (for
domestic manufacturers) to the manufacturing licence or (for overseas
manufacturers) to the GMP clearance have been notified to and authorised by the
TGA.
h. All internal audits and supplier audits have been carried out as required by the
quality management system.
1
For investigational medicinal products this should be interpreted as compliance with the relevant
details of the trial dossier specifications and/or with the application for a Marketing Authorisaton.
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The AP should in addition take into account any other factors of which he/she is aware
which are relevant to the quality of the batch.
2.2 An AP should maintain his/her knowledge and experience up to date in the light of
technical and scientific progress and changes in quality management relevant to the
products which he/she is required to release.
2.3 If an AP is called upon to perform release for supply of a batch of a product type he/she
is unfamiliar with, for example because the manufacturer for whom he/she works
introduces a new product range or because he/she starts to work for a different
manufacturer, the AP should first ensure that he/she has gained the relevant knowledge
and experience necessary to fulfil this duty.
2.4 The PIC/S Guide to GMP identifies some responsibilities that are shared between the
manufacturer and the sponsor (marketing authorisation holder) and that involve the AP.
a. The responsibility to ensure that the quality review is performed in a timely
manner and is accurate, as outlined in GMP clause 1.4.
b. The responsibility to monitor product stability in an on-going stability program,
as outlined in GMP clauses 6.23 – 6.33.
The AP responsible for release for supply is either involved in both preparation of PQRs
and the on-going stability program, or has the full results of these available, as the AP must
consider the results of both as part of release for supply.
3. Manufacture in different locations
3.1 Manufacture, including quality control testing, of a batch of medicines takes place in
stages which may be conducted at different sites and by different manufacturers that may
be located within Australia or overseas. In all cases, each stage should be conducted in
accordance with the requirements outlined above in section 2.1.
3.2 Each site located in Australia should be licensed under the Act for the manufacturing
steps performed, while each site located overseas should be covered by a current TGA
GMP clearance. Regardless whether located in Australia or overseas, each site should have
at its disposal the services of at least one AP.
3.3 The AP responsible for release for supply of the finished product batch cannot always
be closely involved with every stage of manufacture, specifically where different steps in
manufacture occur in different locations. Therefore, under the conditions outlined in
section 3.4 below, the AP performing release for supply of the finished product batch is
allowed to rely in part on decisions(s) of one or more other APs. to release the bulk or
intermediate for supply to the next step in manufacture. This can be either an AP working
within the same company (on the same site or on a different site) or an AP working with
another manufacturer.
3.4 The AP responsible for release for supply of the finished product batch can only rely on
decisions by other APs to release an intermediate or bulk for supply to the next step in
manufacture (i.e. partial manufacture) if all of the following conditions are met.
a. All partial manufacturers in the supply chain are covered by valid GMP
agreements in accordance with chapter 7 of the PIC/S Guide to GMP. These
agreements should each define the release for supply to the next manufacturer in
the supply chain as applicable.
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b. All AP(s) involved, including the APs at sites of partial manufacture are provided
full access to all parts of the Marketing Authorisation that are relevant for the
steps in manufacture performed at the site for which they are the AP.
c. Additional details regarding the release process are provided in the relevant
release procedures in the quality management systems of the manufacturers
involved.
d. All decisions to release for supply to the next step in manufacture are recorded
through a legally valid signature, for example a full written signature on a paper
document or an electronic signature in a validated electronic environment.
e. The AP performing release for supply of the finished product batch has accepted
the quality management system used for this release for supply to the next step
in manufacture, for example through a supplier audit.
The AP performing release for supply of the finished product batch is ultimately
responsible to ensure these conditions are being met when relying on other AP’s release
decisions.
3.5 The GMP agreement should comply with the requirements of GMP chapter 7,
specifically clause 7.11 to specify the way in which the AP responsible for release for
supply of the finished product batch ensures that each batch has been manufactured and
checked for compliance with the Marketing Authorisation.
3.6 Where bulk or intermediate product is manufactured on a different site, the GMP
agreement should include an obligation on the part of the provider of a bulk or
intermediate product to notify the recipient(s) of any significant deviations, out-of-
specification results, non-compliance with GMP, investigations, complaints or other
matters which should be taken into account by the AP who is responsible for release for
supply of the finished product batch.
3.7 Where computer systems are used for recording release for supply decisions,
particular note should be taken of Annex 11 of the PIC/S Guide to GMP.
3.8 Whatever particular arrangements are made for release for supply, it should always be
possible to identify and recall without delay all products which could be rendered
hazardous by a quality defect in the batch.
3.9 Where the ARTG entry of a medicine allows more than one site for release for supply of
the finished product batch, the Australian sponsor should be able to identify the site at
which any particular batch has been released for supply to the Australian market and the
AP who was responsible for releasing that batch. These details should be specified in the
batch records reviewed by the AP for release for supply.
4. Release for supply at manufacturing sites outside
Australia
4.1 Release for supply by an AP located at an overseas manufacturer is recognised within
Australia provided all of the following conditions are met.
a. The manufacturing steps performed are covered by a current GMP clearance.
b. A GMP agreement is in place clearly defining mutual responsibilities.
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c. The ARTG entry reflects the release for supply step being performed by the
overseas manufacturer.
4.2 Where release for supply (regardless whether it is release for further processing of
intermediate/bulk for supply to a next manufacturer or release for supply of a finished
product for importation into Australia) is performed by an AP located at an overseas
manufacturer, the Australian sponsor is responsible for putting arrangements in place to
ensure the AP can effectively take this responsibility.
4.3 Release for supply arrangements with overseas manufacturers are assessed and
verified through on-site GMP inspection and/or the Compliance Verification (CV) process
via the GMP agreement(s) with their contract givers and the assessment of the release for
supply procedures including marketing authorisation requirements.
5. Responsibilities of the AP in relation to product
quality review (PQR)
5.1 The preparation of PQRs is a shared responsibility between the sponsor and the
manufacturer(s) of a product. The mutual responsibilities with regards to PQRs should be
detailed in the relevant GMP agreements between the sponsor and the manufacturer(s).
5.2 Sponsors are also expected to have access and contribute to the PQRs, specifically in
relation to marketing authorisation variations and market complaints, to ensure product
compliance with the Marketing Authorisation.
5.3 PQRs are expected to be available for review during on-site GMP inspections of
manufacturers of products for which the inspected manufacturer is responsible to
perform release for supply.
5.4 During GMP inspections of (contract) manufacturers performing manufacturing steps
prior to release for supply but not the actual release for supply itself, the PQR data
relevant to that manufacturing step submitted to the manufacturer performing release for
supply are expected to be available for review.
5.5 Where multiple manufacturers are involved in the manufacture of a product, each
(contract) manufacturer will normally prepare the data for the PQRs of the manufacturing
steps performed by that manufacturer and submit these data to the manufacturer
performing release for supply of the finished product batch. The manufacturer responsible
for release for supply will then collate the data into complete PQRs. The AP performing
release for supply of the finished product batch must consider those results as part of
release for supply. Other arrangements can be considered, as long as all the relevant data
are provided to one manufacturer in the supply chain or to the sponsor who prepares
complete PQRs. In that case, the other arrangements must be clearly defined in all
applicable GMP agreements.
6. Responsibilities of the AP in relation to on-going
stability testing
6.1 The responsibility to run an on-going stability program of the finished product is
shared between the manufacturer responsible for release for supply and the sponsor.
Actual studies in the on-going stability program can be contracted out to third parties, but
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both the manufacturer responsible for release for supply and the sponsor are expected to
have access to the analytical test results and review those. The AP must consider those
stability results as part of release for supply process.
6.2 Where studies in the on-going stability program are contracted out to third parties,
these laboratories do not necessarily have to be TGA approved. Other certificates may be
used in lieu of a GMP certification, such as a current Good Laboratory Practice (GLP)
certificate or licence issued by a regulatory authority acceptable to the TGA or a current
ISO 17025 accreditation certificate. Stability test methods used by the laboratory should
be appropriately validated and documented according to the requirements of the PIC/S
Guide to GMP. The AP must consider this as part of release for supply.
6.3 Following GMP clause 6.25, manufacturers performing manufacturing but not
performing release for supply of finished product batches, are expected to consider
inclusion of the intermediate product in the steps they perform, in an on-going stability
program. This could be their own on-going stability program, or the program run by the
manufacturer responsible for release for supply, as long as both the AP performing release
for supply of the finished product batch and the sponsor have access to the results.
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Part 2: Specific considerations
for specific areas of
manufacture
Text yet to be drafted pending industry input
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Glossary
In the context of this guidance document, certain words and phrases are used with the
particular meanings defined below. Reference is also be made to the Glossary in the PIC/S
Guide to GMP.
Authorised Person (AP): an individual employee authorised by the manufacturer through
a statement in the manufacturer’s quality management system to perform release for
supply. The AP is recognised by the authority as having the necessary basic scientific and
technical background and experience.
Bulk production batch: a batch of product, either ready for assembly into final containers
or in individual containers ready for assembly to final packs. (A bulk production batch
may, for example, consist of a bulk quantity of liquid product, of solid dosage forms such as
tablets or capsules, or of filled ampoules).
Finished product batch: with reference to the control of the finished product, a finished
product batch is the batch of product in its final pack for release for supply to the market.
GMP agreement: a written contract covering the manufacture and/or analysis arranged
under contract and any technical arrangements made in connection with it.
Marketing authorisation: the details of the medicine involved in the Australian Register
of Therapeutic Goods (ARTG), as well as all other matters in relation to the product
registration or listing agreed in writing between the TGA and the sponsor.
PIC/S Guide to GMP: The Guide to Good Manufacturing Practice for Medicinal Products ,
published by the Pharmaceutical Inspection Cooperation Scheme (PIC/S)under document
number PE 009 in its version as determined in the current Manufacturing Principles.
Release for supply: certification by an Authorised Person that each production batch has
been produced and controlled in accordance with the requirements of the marketing
authorisation and any other regulations relevant to the production, control and release of
medicinal products. Release for supply can be distinguished in the following categories.
a. Release for supply to the Australian market (of a finished product batch);
b. Release for further processing (of an intermediate or bulk product) to the next
step in manufacture;
c. Release of investigation medicinal products for use in human clinical trials;
d. Release for export.
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List of acronyms used
AP: Authorised Person
API: Active Pharmaceutical Ingredient
ARTG: Australian Register of Therapeutic Goods
BP: British Pharmacopoeia
EP: European Pharmacopoeia
GLP: Good Laboratory Practice
GMP: Good Manufacturing Practice
ISO: International Organisation for Standardisation:
www.iso.org
OOS: Out-of-specification (result)
PIC/S: Pharmaceutical Inspection Cooperation Scheme:
www.picscheme.org
PQR: Product Quality Review
TGA: Therapeutic Goods Administration
TGO: Therapeutic Goods Order
USP: United States Pharmacopoeia
Therapeutic Goods Administration
PO Box 100 Woden ACT 2606 Australia
Email: [email protected]ov.au Phone: 1800 020 653 Fax: 02 6232 8605
www.tga.gov.au
Reference/Publication # R13/376659
