MANUFACTURERS LICENSING SCHEME

GMP Audit Checklist for MANUFACTURERS

Form: KP80_F33

Company Name

Date of Audit

Audit
Conducted By

This form is intended for internal use by Manufacturers and will not normally be used by APVMA-Authorised
Auditors during GMP audits.

This checklist lists the major points which will be addressed by the GMP auditors when auditing a manufacturing
premises against the Australian Code of Good Manufacturing Practice for Veterinary Chemical Products, 2007
(and relevant annexes). Attention to the matters on this checklist will assist manufacturers to meet their obligations
in upcoming GMP audits.
Each item in the checklist should be assessed for level of compliance with the GMP Code, using the following
criteria:
Acceptable - satisfactory or substantial compliance with the GMP Code;
Minor non-conformance minor or less serious non-conformance which may not pose a risk to product quality;
Major non-conformance failure to satisfy a key or mandatory requirement and/or one which may pose a risk to
product quality;
Critical non-conformance a major non-conformance which poses a risk to treated animals or users and must be
corrected immediately (indicate with a C in the major non-conformance column).

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CORE ELEMENT 1

KP80_F33

QUALITY MANAGEMENT

Manufacturing principles
Manufacturers of veterinary chemical products must have in place a quality assurance system to ensure that finished products are fit for their intended use, comply with
registration requirements and do not place treated animals or users at risk due to inadequate quality, safety or efficacy.
The quality assurance system must ensure that:

appropriate procedures are in place to ensure that relevant quality standards are met

all materials involved in the manufacturing process comply with required quality standards before they are released for use in manufacture

there are measures designed to prevent cross-contamination

there are safeguards and controls in place designed to prevent the occurrence of foreseeable errors or process failures

finished products have been made and stored correctly and they comply with required quality standards before they are released for supply.
The quality assurance system must be relevant to the nature and intended use of the product. It must be fully documented, monitored for effectiveness and provide for
continuous improvement.

Management of quality
Check
Point
No.

Checkpoint

Acceptable

101

Documented quality assurance system, supported by management, in place. Quality requirements are understood,
implemented and maintained at all levels of the organisation. Adequate resources provided to achieve this.

102

A senior manager has responsibility for the overall direction and management of quality within the organisation.

103

Management reviews the quality assurance system at stated, regular intervals (no greater than every three years), to
ensure the continued suitability, adequacy and effectiveness of the system, and its continual improvement. That
review evaluates any changes to the quality system that have taken place. Management review process documented
and records of the review maintained.

Minor
non
conformance

Major
non
conformance

Not
Audited

Quality assurance
104

The quality assurance system ensures that:

(a)

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managerial responsibilities are clearly defined, documented and exercised;

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Check
Point
No.

Checkpoint

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Acceptable

(b)

production and control operations are clearly specified and good manufacturing and good laboratory practices
are followed;

(c)

starting and packaging materials meet required specifications utilising vendor assurance where possible;

(d)

all necessary controls on intermediate products and in-process controls are carried out;

(e)

all necessary validations are carried out;

(f)

finished products are not supplied before an authorised person has certified that each batch has been produced in
accordance with documented procedures, meets required specifications that are consistent with product
registration, and meets all required quality tests;

(g)

appropriate environmental and storage conditions are maintained;

(h)

there is a procedure for conducting internal quality audits (self inspections) that regularly appraise the
effectiveness and application of the quality assurance system.

Minor
non
conformance

Major
non
conformance

Not
Audited

Quality control
105

A system of quality control is in place to ensure that products comply with their required specifications and standards,
as described in Chapter 8 of the GMP Code.

Quality and production nominees

106

The responsibilities for Quality and for Production are allocated to specific persons. Those nominated for these
responsibilities are, where practicable, different persons, neither responsible to the other. They are suitably qualified,
trained or experienced as described in Chapter 2 of the GMP Code.

107

The persons responsible for Production and Quality have effective control over any manufacturing steps carried out at
all premises covered by the manufacturing licence.

108

The person nominated as being responsible for Production has the necessary authority to control manufacture of the
product. The usual duties of that person are described more fully in Chapter 2 of the GMP Code.

109

The person nominated as being responsible for Quality has the necessary independence and authority to ensure that
quality measures are employed in the production and testing of product and that product is not released until judged to
be satisfactory. The usual duties of that person are described more fully in Chapter 2 of the GMP Code.

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Check
Point
No.

110

Checkpoint

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Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Where operational events and quality policy conflict, the person nominated as being responsible for Quality has the
authority to make a decision to resolve the conflict. Such circumstances and the decision are recorded.

Process control and change control

111

All critical steps in the manufacturing process, and any changes to these steps, are documented. Manufacturing
processes are reviewed at defined regular intervals and the outcome of that review is documented and acted upon.

112

A change control system is in place to manage significant manufacturing and product quality changes. This includes
provision to notify the APVMA, as the registration authority, of variation in product details where necessary.

Key observations and comments (Comment on both positive and negative aspects of Quality Management. Record evidence sighted and reviewed, such as policy
documents, records, etc, particularly with respect to non-conformance) .

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CORE EMEMENT 2

KP80_F33

PERSONNEL AND TRAINING

Manufacturing principles
Veterinary chemical products must be manufactured under the management and supervision of appropriately qualified, trained or experienced persons who:

understand the specialised technical, quality and legal requirements relating to the manufacture of veterinary chemical products for which they have responsibility

have their duties and responsibilities clearly defined by the manufacturer.

Manufacturing staff must be trained to a satisfactory level of competency in:

the basic principles of good manufacturing practice

the specific duties, in connection with the manufacture of veterinary chemical products, that they are required to perform.
There must be a sufficient number of competent personnel to carry out all required tasks.

General
Check
Point
No.

Checkpoint

Acceptable

201

The manufacturer has an adequate number of personnel with the necessary qualifications, training or practical
experience. The responsibilities placed on any one individual are not so extensive as to present a risk to quality.

202

The manufacturer has an organisational chart showing the names of key personnel, as well as their areas of
responsibility and lines of authority.

203

People in responsible positions have written job descriptions describing their specific duties. There are no gaps or
unexplained overlaps in the responsibilities of those personnel concerned with the application of GMP.

204

People in responsible positions have adequate authority to carry out their responsibilities.

205

Where the duties of persons in responsible positions are delegated to designated deputies with relevant qualifications
and experience, records are kept of those delegations.

206

Operators verbal and written communication skills are sufficient for them to respond to training, accept and
implement instructions exactly and, where their duties require it, fill out forms correctly.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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Key personnel
Check
Point
No.

Checkpoint

Acceptable

207

Key personnel include the persons nominated as responsible for Production and for Quality and, if neither of these
persons is responsible for product release, the person(s) authorised for that purpose. Key positions are occupied by
full-time personnel.

208

The persons responsible for Production and for Quality are independent from each other. In small operations where
this may not be possible, the quality control function and procedures are clearly documented and shown to be
effective.

209

The person with overall responsibility for Production has responsibility to:

210

(a)

ensure that products are produced and stored according to documented procedures

(b)

approve procedures relating to production operations and ensure their strict implementation

(c)

approve and monitor any subcontracted production work

(d)

ensure that production records are evaluated and signed by an authorised person before they are submitted for
product release

(e)

ensure that production areas, premises and equipment are maintained to an appropriate standard

(f)

ensure that appropriate validations are conducted

(g)

ensure that initial and continuing training of production personnel are conducted, according to need.

Minor
non
conformance

Major
non
conformance

Not
Audited

The person with overall responsibility for Quality has responsibility to:
(a)

evaluate and authorise master manufacturing and packaging documents

(b)

approve specifications, sampling instructions, test methods and other quality control procedures

(c)

approve or reject raw materials, packaging materials, and intermediate, bulk and finished products

(d)

review completed batch records as part of the release procedures

(e)

ensure that all necessary testing is carried out

(f)

approve and monitor any contract analysts

(g)

monitor quality performance of subcontract manufacturers

(h)

check the maintenance of the quality control area, premises and equipment

(i)

ensure that appropriate validations are conducted

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Key personnel (cont)

Check
Point
No.

Checkpoint

Acceptable

(j)

ensure that initial and continuing training of quality control personnel are conducted, according to need

(k)

approve and monitor the suppliers of materials.

Minor
non
conformance

Major
non
conformance

Not
Audited

Other duties relating to quality control are summarised in Chapter 8 of the GMP Code.
211

Where the persons responsible for Production and Quality have some shared or jointly-exercised responsibilities, their
primary roles are not compromised.

Qualifications and experience

212

The persons responsible for Production and Quality have a relevant scientific qualification at tertiary level and/or have
had relevant practical experience and the necessary competencies in the manufacture of products in accordance with
GMP requirement

Training and competency assessment

213

Training provided for all personnel whose duties take them into production areas or into quality control laboratories,
including technical, maintenance and cleaning personnel. Training also given to other personnel whose activities
could affect product quality. Particular attention given to the training needs of casual employees.

214

Training programs are appropriate to the identified needs of staff and are approved by the head of either Production or
of Quality, as appropriate. The effectiveness of the training program is monitored.

215

Training programs include initial training in the basic principles of GMP, as well as training appropriate to the duties
assigned to staff. Programs also include ongoing training and refresher training, including training in changes to the
manufacturing process and procedures. Training programs specifically address the concept of quality assurance, as
well as relevant aspects of sanitation and personal hygiene.

216

Records are kept of all internal and external training programs and the various training activities undertaken by
individual staff.

217

Staff are assessed for their competence to perform the duties assigned to them. Records are kept of those assessments.

218

Personnel working in areas where contamination is a hazard (eg cleanrooms or areas where highly active, toxic,
infectious or sensitising materials are handled) are given specific training in those aspects of manufacture.

219

Personnel have a clear understanding of their responsibilities.

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Training and competency assessment (cont)

Check
Point
No.

Checkpoint

Acceptable

220

Personnel are not be required to, or allowed to, sign or initial a document unless they have been trained and assessed
as competent in the work practices associated with the signature and in the significance of the signature.

221

A register of staff signatures and initials is maintained. Entries are updated at regular stated intervals and the previous
records archived.

222

Visitors or untrained personnel are not normally taken into active production and quality control areas. If access is
unavoidable, they are adequately supervised and given information in advance, particularly about personal hygiene
and prescribed protective clothing.

Minor
non
conformance

Major
non
conformance

Not
Audited

Personal hygiene and health issues

223

Detailed hygiene programs are established and adapted to meet the needs of the different areas within the
manufacturing facility. They include procedures relating to the health, personal hygiene practices and clothing of staff.
These procedures are understood and followed by every person whose duties take them into the production and quality
control areas.

224

Where relevant, production personnel are subjected to medical examination to ensure that their health status does not
pose a risk to product quality and that they are able to carry out required tasks (eg visual checks of labels or
containers).

225

Staff are made aware of the need to draw managements attention to any health problems that might affect product
quality. Steps are taken to ensure that anyone affected by an infectious disease, or having open lesions on an exposed
surface of the body, is not engaged in activities where operator-borne contaminants may pose a risk to product quality.

226

Every person entering the manufacturing or quality control areas wears protective garments appropriate to the
operations carried out there.

227

Protective clothing is cleaned and/or replaced at fixed intervals or when soiled, and kept in good condition. When
necessary, soiled clothing is decontaminated before being laundered (eg clothing from areas where live
microorganisms are being cultured). Where garments are laundered off-site, any special precautions required to avoid
harm to personnel or the environment are specified. Protective clothing is not be worn outside the factory premises.

228

Eating, drinking, chewing, smoking, or the storage of food, drink, smoking materials or personal medication is not
allowed in the production, packaging, storage, or laboratory areas. Relevant signs are displayed at prominent positions
at entry points to these areas.

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Personal hygiene and health issues (cont)

Check
Point
No.

Checkpoint

Acceptable

229

Direct contact is avoided between the operators hands and the exposed product or any part of the equipment that
comes into contact with the product.

230

The wearing of jewellery that may become detached or caught in machinery is discouraged in manufacturing areas.

Minor
non
conformance

Major
non
conformance

Not
Audited

Key observations and comments (Comment on both positive and negative aspects of Personnel and Training. Record evidence sighted and reviewed, such as policy
documents, SOPs and records, particularly with respect to non-conformance) .

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CORE ELEMENT 3

KP80_F33

BUILDINGS AND GROUNDS

Manufacturing principles
Veterinary chemical products must be manufactured in buildings that are located, designed, constructed, maintained and utilised to:

suit the operations carried out in them

ensure protection of the veterinary chemical products from contamination

permit effective cleaning and maintenance, including cleaning after processes have been completed

minimise the risk of manufacturing error.

The products must also be manufactured in an environment, or in equipment fitted with precautionary measures, that:

ensures a standard of hygiene appropriate to the class of veterinary chemical product being manufactured

minimises the risk of cross-contamination of the finished product, or of materials or components that are used or manufactured at the premises

ensures the safety of operators and protects the outside environment.

General
Check
Point
No.

Checkpoint

Acceptable

301

Premises are situated in an environment that presents minimal risk of causing contamination of materials or products.
(For example, locations in close proximity to chemical works or trades likely to result in pollution or contamination of
product are avoided unless special precautions are taken).

302

The premises, including the surrounding grounds and gardens, are kept in an orderly, neat and tidy condition.

303

Premises are designed, constructed and maintained to minimise the effects of weather and ground seepage, the entry
and accumulation of dust and other airborne materials, and the entry of insects, birds, rodents, vermin and other
animals. Cavities and voids are minimised and, where necessary, provided with access for pest control purposes.

304

Each part of the premises is suitable for the operations being carried out and kept in good repair. Repair and
maintenance operations do not present any hazard to product quality.

305

Lighting, temperature, humidity and ventilation are appropriate for the type of operations being undertaken. They do
not directly or indirectly, adversely affect product quality during manufacture and storage, or the accurate functioning
of equipment. Air intakes are located away from sources of contamination.

306

Sinks are made of stainless steel, without overflow and preferably spaced 50 mm away from walls so as to avoid
uncleanable joins and crevices. Where appropriate, they have effective, easily cleanable traps and air breaks to
prevent backflow.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Buildings and grounds general (cont)

Check
Point
No.

Checkpoint

Acceptable

307

Floor drains are generally avoided. Where necessary, they are of adequate size, flush with the floor, screened and
trapped. Drains are underground. Open channels generally avoided, but, if necessary, are shallow to facilitate
cleaning and disinfection.

308

Production and quality control areas are not used as passageways by personnel who do not work in them, or for the
transport of materials not being currently used in them. They are not used as storage areas for obsolete materials or
equipment.

309

The premises are secured against entry of unauthorised personnel or materials. Visitors to the premises, including
external maintenance workers and contractors, are supervised and restricted to an appropriate level of access.

Minor
non
conformance

Major
non
conformance

Not
Audited

Cleaning and sanitation

310

Processing areas, laboratories and storage areas are kept in a clean, sanitary and orderly condition.

311

Documented cleaning procedures are available for all areas. These describe:
(a)

the areas to be cleaned, the frequency of cleaning, and specific requirements of individual areas;

(b)

the materials, concentrations and equipment to be used;

(c)

the methods used to decontaminate cleaning equipment.

312

Where the removal of traces of product is critical, evidence to demonstrate that the cleaning process is effective is
available. (In these cases, unless standards of cleanliness are prescribed by a regulatory authority, manufacturers
should determine appropriate limits based on assessed risk).

313

Waste material are deposited in suitable, appropriately located and labelled containers and appropriately disposed of at
frequent intervals. Where necessary, effluent is treated before disposal.

314

The premises are kept free of insects, birds, rodents, and other animals, either by containment or by appropriate
control measures. A documented pest control program is in place, which is monitored for effectiveness. Records
describe the location of bait stations, materials used, monitoring frequency and effectiveness.

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Storage areas (including receipt and despatch )

Check
Point
No.

Checkpoint

Acceptable

315

Storage areas are organised and of sufficient area to permit the effective separation and identification of the various
materials and products stored in them. Materials or products that are rejected, returned or recalled are segregated and
secured.

316

Storage areas provide storage conditions appropriate to the materials and products held in them. In particular, they are
clean, dry, and maintained within acceptable temperature limits. Where special storage conditions are required (eg
temperature and humidity) these are provided and monitored. (Note that these requirements do not preclude outdoor
storage of materials where outdoor storage does not adversely affect quality).

317

Where a controlled storage temperature is critical for the maintenance of material or product quality, the environment
is controlled, monitored and recorded, as follows:
(a)

there are temperature recording devices, and records are under regular review;

(b)

there is an alarm and/or visual signal to indicate that a storage temperature control system has failed; the system
permits resetting only by authorised personnel and is checked at regular, stated intervals.

318

Refrigerators, cold rooms and freezers are regularly defrosted and cleaned. In the event that a refrigeration storage
facility is shut down, total cleaning occurs.

319

Receiving and despatch bays protect materials and products from the weather and are designed and equipped to allow
containers of incoming materials to be cleaned, where necessary, before storage.

320

On receipt, all starting materials (including labels, printed cartons and other packaging material) are subject to
effective quarantine and release control.

321

Where quarantine status is ensured by storage in separate areas, these areas are clearly marked. Any system replacing
a physical quarantine system (such as a computerised access system) provides at least an equivalent level of security.

322

Sampling of raw materials is conducted in such a way that contamination of the material, or cross-contamination of
other materials, is prevented. There is a separate sampling area for highly active, hazardous or toxic raw materials.

323

Highly active, hazardous or toxic materials or products, or otherwise incompatible materials are stored in such a way
as to not pose a risk to other materials or products.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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Production areas
Check
Point
No.

Checkpoint

Acceptable

325

The operations carried out in any particular area are compatible, so that the integrity of any product made in the area is
not threatened.

326

Manufacture of sterile, highly active, toxic or infective products is normally performed in dedicated, self-contained
facilities. Processes that may give rise to significant risk from cross-contamination also require such facilities. (Note
that campaign manufacture in the same facilities may be accepted, provided that specific, documented precautions
are taken).

327

Registered veterinary medicinal products are not manufactured in the same areas as poisonous, toxic or hazardous
unregistered consumer products.

328

Veterinary chemical products containing technical poisons are handled in segregated areas or separate buildings,
usually with equipment dedicated to this class of product. (However, common areas or equipment may be accepted,
provided that cross-contamination is controlled by scheduling or use of a validated cleaning procedure).

329

Premises are laid out in a way that allows the orderly and logical positioning of equipment and materials so as to
minimise the risk of confusion between different veterinary chemical products or their components, to avoid crosscontamination and to minimise the risk of omission or wrong application of any of the manufacturing or control steps.

330

Where starting and primary packaging materials, or intermediate or bulk products are exposed to the environment,
interior surfaces (walls, floors and ceilings) are suitable for the class of product being manufactured. (This will
usually require surfaces that are nonporous, smooth, free from open joints, and do not shed particulate matter).
Interior surfaces permit effective cleaning.

331

Joins between walls and floors are easy to clean, adequately sealed and where appropriate, coved to form a smooth
curve between the floor and wall.

332

Wood or wood-based materials are avoided as a material of construction or support for equipment or materials in
production areas, especially where they may be wetted. If used, they are sealed with a coating that is resistant to
chipping, disinfectants and cleaning agents and that is easily cleaned.

333

The use of wood-based pallets is avoided in production areas where there is a risk of contamination of the product.

334

Pipe work, light fittings, ventilation points and other services are designed and located to avoid the creation of recesses
that are difficult to clean. As far as practicable, they are accessible from outside the manufacturing areas for
maintenance purposes.

335

Production areas are effectively ventilated and allow, where necessary, control of air flow, temperature, humidity and
filtration appropriate to the products handled, the operation undertaken and the external environment.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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Production areas (cont)

Check
Point
No.

Checkpoint

Acceptable

336

The arrangements for weighing or measuring raw materials minimise cross-contamination. (This may require the use
of separate weighing or dispensing rooms designed and reserved for that us)e. Dispensing rooms are not used as
storage areas for starting and other materials.

337

Where dust is generated (eg during sampling, weighing, mixing and processing operations, or packaging of dry
products), specific provisions are made and precautions taken, to avoid cross-contamination (eg efficient dust
extraction, use of dedicated enclosed areas) and to facilitate cleaning.

338

Materials likely to shed fibres or other contaminants, such as wooden pallets or fibreboard, are not taken into areas
where products or clean containers are exposed.

339

Production areas are well lit, particularly where visual on-line controls are carried out.

Minor
non
conformance

Major
non
conformance

Not
Audited

Quality control areas

340

Quality control laboratories are separated from production areas. This is particularly important with laboratories that
handle microorganisms.

341

Quality control laboratories are designed to suit the operations carried out in them. Space is sufficient to avoid mixups and cross-contamination. There are adequate storage for samples and records.

342

Sensitive instruments are protected from adverse effects such as vibration, electrical interference, and humidity

Ancillary areas
343

Staff amenities, including lunch rooms, are separate from storage, production and quality control areas.

344

Clean and well-ventilated toilets and changing rooms are provided. These are easily accessible and suitably isolated
from any production, quality control or storage areas. They are appropriate for the number of users and are maintained
in a tidy and hygienic manner, with an adequate supply of hot and cold water, soap and hygienic hand-drying facilities.

345

A sufficient number of clean hand basins, with a satisfactory supply of hot and cold water, soap or detergent
dispensers, and hygienic hand-drying facilities are provided near working areas for use by production personnel.

346

Maintenance workshops should, as far as possible, be separate from production areas. Whenever parts or tools are
stored in the production area, they are kept in rooms or lockers reserved for that use.

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Animal houses
Check
Point
No.

347

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Areas in which animals are housed are adequately isolated from storage and processing areas, with separate access for
animals and separate air handling facilities.

Key observations and comments (Comment on both positive and negative aspects of Buildings and Grounds. Record evidence sighted and reviewed, such as SOPs,
records and observations, particularly with respect to non-conformance) .

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CORE ELEMENT 4

KP80_F33

EQUIPMENT

Manufacturing principles
Equipment used in the manufacture of veterinary chemical products must be suitable for its intended purpose and appropriately operated, maintained and cleaned. Equipment
must be correctly installed and operated in accordance with written instructions that are appropriate for the equipment.
The design and layout of equipment must be such that:

the risk of manufacturing error is minimised

effective cleaning and maintenance are possible, in order to avoid cross-contamination of either intermediate materials or the finished product, the buildup of dust or dirt
and, in general, to avoid any adverse environmental effect on the quality of the product.

General
Check
Point
No.

Checkpoint

Acceptable

401

Equipment used for the manufacture (including testing) of veterinary chemical products, is designed, located and maintained to suit
its intended purpose and installed and positioned in such a way as to minimise any risk of error or cross-contamination.

402

Equipment is used in accordance with written instructions that are appropriate to the equipment and consistent with any operating
instructions issued by the equipment manufacturer.

403

Production equipment does not present any hazard to the manufactured products (eg by contamination of processed materials or
finished products, or their containers, with lubricants or other extraneous substances). The parts of the production equipment that
come into contact with materials being processed or the finished product are not reactive, additive, or absorptive to such an extent
that product quality is adversely affected.

404

Equipment is uniquely identified. This identification is traceable to all records pertaining to the equipment.

405

If prone to failure or variance, equipment used for critical steps in the manufacturing process is monitored by devices capable of
recording the necessary operating parameters, or is equipped with alarm devices to indicate malfunction. If such devices are not
practical, the output is monitored to ensure early detection of variance.

406

Balances and other measuring equipment required for production and quality control operations are available and have an
appropriate range and degree of precision. Equipment is properly positioned before use.

407

Fixed pipe-work is clearly labelled to indicate the contents and, where applicable, the direction of flow. Pipes are adequately sloped
for drainage and constructed without dead-legs. There are measures in place to ensure that materials transferred via pipelines are
delivered to the correct destination.

408

Defective equipment is, where possible, removed from production and quality control areas. If it cannot be removed, it is clearly
labelled as defective.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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Equipment qualification and validation

Check
Point
No.

Checkpoint

Acceptable

409

Newly installed equipment that is critical to the manufacturing process is formally commissioned. There are protocols
for installation qualification (IQ) and operation qualification (OQ) of equipment. These include the development and
implementation of procedures for operation, calibration, maintenance and cleaning.

410

Equipment that has been taken out of service, modified or undergone major repairs is formally approved for re-entry
into service.

Minor
non
conformance

Major
non
conformance

Not
Audited

Maintenance
411

All equipment is properly maintained and records of this maintenance are kept. In addition, equipment is inspected for
serviceability before any operation begins.

412

Repair and maintenance operations do not present any hazard to product quality.

413

Where continued maintenance of specific equipment is essential to product quality, documented maintenance
procedures and records include the following:
(a)

details and frequency of preventive maintenance requirements;

(b)

action to be taken if equipment maintenance requirements cannot be met;

(c)

records of preventive maintenance, including the name of the service-person , any deviation from the procedure
and a statement or authorising signature documenting the condition of the equipment following the service.

Calibration
414

Each item of equipment used in manufacture or for quality control purposes that measures, or depends on, a physical
parameter (eg measuring, weighing, recording and control equipment), is calibrated at defined intervals, in accordance
with a written procedure. That procedure describes the method and frequency of calibration or observation, taking
into account any statutory requirements, as well as the action to be taken when results deviate from defined acceptance
limits.

415

Where appropriate, verification checks are performed at a frequency consistent with the use of the equipment, in
accordance with a written procedure.

416

Records are kept of any calibrations, verification checks or observations carried out on such equipment. Those records
contain sufficient information to show that the required calibrations/observations have been carried out and provide
details of any necessary corrective action taken.

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Calibration (cont)
Check
Point
No.

Checkpoint

Acceptable

417

Equipment calibration records show the actual results observed and the acceptance criteria.

418

Where practicable, each item requiring calibration bears a label or tag indicating that calibration has been carried out
and when the next calibration is due. (Alternatively, a computer-based maintenance system that flags the need for
calibration can be accepted, provided that it can be shown to be working effectively).

419

There is evidence to demonstrate that the particular calibrating devices used are themselves accurate. Contractors who
calibrate equipment are certified by a certification agency.

Minor
non
conformance

Major
non
conformance

Not
Audited

Cleaning
420

Manufacturing equipment is designed so that it can be easily and thoroughly cleaned. Where necessary, it is easily
dismantled for cleaning. It is cleaned according to detailed written procedures, and stored only in a clean, dry
environment. Records are kept of equipment cleaning operations.

421

To facilitate cleaning, equipment is mobile or clear of walls and floors. Where this is not practical, equipment is
sealed to the surfaces it touches.

422

Permanently fixed product and process-water pipelines have sanitary couplings and are sloped for drainage.

423

Washing and cleaning equipment is chosen and used in such a way that it is not a source of contamination.

424

Pipes for distilled, purified and, where appropriate, other water are sanitised according to written procedures that
describe the action limits for microbiological contamination and the measures to be taken if action limits are exceeded.

425

Equipment is cleaned to the frequency and extent necessary to preserve product integrity. A cleaning record is kept
either on the batch record or in an equipment log book.

426

Validation of cleaning procedures is considered where traces of ingredient may pose significant risk of contamination
or toxicity in following product batches.

Key observations and comments (Comment on both positive and negative aspects of Equipment. Record evidence sighted and reviewed, such as SOPs, records and
observations, particularly with respect to non-conformance).

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CORE ELEMENT 5

KP80_F33

DOCUMENTATION

Manufacturing principles
Manufacturers of veterinary chemical products must establish and maintain a system of documentation, document control and record keeping that:

provides precise specifications for starting materials, intermediate materials and finished products, manufacturing formulae and instructions and operating procedures for
associated manufacturing and quality control activities

provides a complete history of each item, batch, or quantity manufactured in a specified timeframe, of veterinary chemical product produced at the premises

establishes a traceable connection between raw materials and the finished product.

General
Check
Point
No.

Checkpoint

Acceptable

501

All processes and associated activities in the manufacture of veterinary chemical products are documented and the
documents subjected to a system of document control.

502

Manufacturing documentation is designed, prepared, reviewed and distributed with care. It complies with the relevant
parts of product registration dossiers and registered particulars for the product and is regularly reviewed and kept up to
date.

503

Documents are approved, signed and dated by appropriate and authorised persons. In the case of master
manufacturing formulae, manufacturing instructions, and packaging and labelling instructions, a second authorised
person checks, reconciles, endorses and dates both the formula and instructions.

504

The issue of working documents and forms is limited to photocopying from current, authorised, signed, hard master
documents or printing from access-controlled authorised electronic versions.

505

Documents are legible, readily identifiable and retrievable. They do not include superfluous data and, at the working
level, are written in the imperative (ie as instructions rather than statements of what is desired). They are laid out in an
orderly fashion and are easy to check.

506

Documents are not handwritten. Where data entries are handwritten or machine-printed, they are clear, legible and
permanent. Sufficient space is provided for such entries.

507

The contents of documents are unambiguous. The title, nature and purpose are clearly stated. The document clearly
identifies the way in which it is to be used, and by whom it is to be used. It includes, or is identifiable to, the issuing
premise and also includes the following information:
(a)

KP80_F33

Minor
non
conformance

Major
non
conformance

Not
Audited

a unique number identifying the document;

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KP80_F33

Documentation general (cont)

Check
Point
No.

Checkpoint

Acceptable

(b)

the version number and date it became effective;

(c)

the page number of the total number of pages of the document on each page;

(d)

provision for authorisation.

508

Relevant documentation is available to cover manufacturing and associated activities at all locations.

509

Reproduced documents are clear and legible. The reproduction of working documents from master documents (eg by
photocopying or by computer printout), does not allow error to be introduced through the reproduction process. A
designated competent person should initial each reproduced document before issue to signify that it is complete,
legible and appropriate.

510

Any correction to a document should permit the reading of the original information. Corrections are handwritten
clearly and legibly in permanent ink, and initialled and dated by an authorised person. Where appropriate, the reason
for the alteration is recorded.

511

Where appropriate, new or revised documents are introduced following a formal commissioning and training period.

Minor
non
conformance

Major
non
conformance

Not
Audited

Document control
512

The system of document control is documented. That document definesw the procedures in place for:
(a)

approval and regular review of documented procedures;

(b)

distribution of documents;

(c)

removal of obsolete documents from all points of issue and use;

(d)

prevention of inadvertent use of superseded documents.

513

A documented procedure is in place that defines the controls needed for the storage, protection, retrieval, retention
time and disposal of records.

514

The system of document control includes a list of all controlled documents and identifies the current revision status of
any controlled document and the holder/location of that document.

515

Changes to controlled documents are acted upon promptly. They are reviewed, dated and signed by the authorised
person(s) and formally implemented. There are records to show that all relevant personnel have acknowledged
subsequent changes to procedures.

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KP80_F33

Document control (cont)

Check
Point
No.

516

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Where key documents (eg master manufacturing formulae or master manufacturing instructions, critical cleaning
procedures) have been revised, all associated or linked documents (eg batch manufacturing instructions, batch
documentation) are updated to reflect any relevant changes to the key documents, or be otherwise linked to the revised
documents.

Records
517

Records are made or completed at the time each action is taken.

518

Manufacturing records are retained by the manufacturer for the period specified in the Agricultural and Veterinary
Chemicals Code Regulations 1995, as cited below.

519

Data may be recorded by electronic data processing systems, photographic or other reliable means, but detailed
procedures relating to the system in use are available and the accuracy of the records are checked.

520

If documentation is handled by electronic data processing methods, only authorised persons are able to enter or modify
data in the computer and there is a record of changes and deletions. Access is restricted by passwords or other means.
See Chapter 6 (Computer Systems) of the GMP Code for details.

521

Batch records that are stored electronically are backed up by suitable means on a regular basis. Data are readily
available throughout the period of retention.

522

Consideration is given to storage of batch records and other critical records in a safe and secure environment.

Regulation 61(3) A holder of a licence must make records showing:

(a) the materials used in the manufacture of the chemical products, the supplier and quantities of the materials used and details of the tests performed on those materials; and
(b) the procedures and controls employed in the manufacture of the chemical products, including the results of tests carried out during the processing of the chemical products;
and
(c) details of tests performed on the chemical products and the results of those tests; and
(d) the stability studies (if any) that validate the recommended shelf life and appropriate storage conditions of the chemical products.
Regulation 61(5) A holder of a licence must keep at the premises to which the licence relates:
(a) the records in subregulation (3); and
(b) if it is not unreasonable in the circumstances a sample from each batch of the finished products;
for at least 12 months after the expiry date of the products to which they relate or, if there is no expiry date, for at least 6 years after the date on which the manufacture of the
products was completed.

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KP80_F33

Documents required:
Specifications
Check
Point
No.

Checkpoint

Acceptable

523

There are authorised and dated specifications for starting and packaging materials, as well as finished products,
appropriate for the type of product being made and consistent with data submitted for product registration. Where
appropriate, they are also available for intermediate or bulk products.

524

Specifications for starting and primary or printed packaging materials include, where applicable:
(a)

Major
non
conformance

Not
Audited

a description of the materials, including:

(i)

the designated name and the internal code reference;

(ii)

reference, if any, to a pharmacopoeial monograph, or any other document on which the specification is
based;

(iii)

the approved source of any active material;

(iv)

the preferred suppliers; and, if relevant, the original producer of the materials;

(v)

a specimen of printed materials;

(b)

directions for sampling and testing, or reference to procedures;

(c)

qualitative and quantitative requirements with acceptance limits;

(d)

storage conditions and precautions;

(e)

the maximum period of storage before re-examination;

(f)

any relevant safe handling instructions.

525

Where specifications for raw materials are based on a valid certificate of analysis provided by a supplier, a copy of that
certificate of analysis is suitably identified and authorised by an appropriate person and retained as part of the
manufacturers specifications.

526

Specifications for intermediate and bulk products are available if these are purchased or despatched, or if data obtained
from intermediate products are used for the evaluation of the finished product. The specifications are similar to
specifications for raw materials or for finished products, as appropriate.

KP80_F33

Minor
non
conformance

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KP80_F33

Specifications (cont)
Check
Point
No.

527

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Specifications for finished products include:

(a)

the designated name of the product and the code reference where applicable;

(b)

a description of the pharmaceutical form and package details;

(c)

the qualitative and quantitative requirements, such as visual, organoleptic, physical, chemical and
microbiological, with the acceptance limits;

(d)

the storage conditions, shelf life and any special handling precautions, where applicable.

Materials control (stores receipt, storage and disposal)

528

There are written procedures and records for the receipt of each delivery of each starting material, including immediate
containers and printed packaging material.

529

The records of receipt include:

530

(a)

the name of the material on the delivery note and the containers;

(b)

the in-house name and/or code of material if different;

(c)

date of receipt;

(d)

supplier's name and, if possible, manufacturer's name;

(e)

original manufacturer's batch or reference number;

(f)

total quantity, and number of containers received;

(g)

the unique identifying number (UIN) assigned by the licensed manufacturer after receipt;

(h)

any relevant comment (eg state of the containers).

The records also include confirmation that:

(a)

the goods have come from an approved supplier or, if not, an explanation why;

(b)

the nature and quantity of goods supplied is consistent with the order;

(c)

the goods have been checked for damage;

(d)

a valid certificate of analysis has been supplied for chemicals;

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KP80_F33

Materials control (stores receipt, storage and disposal) cont

Check
Point
No.

Checkpoint

(e)

at least a visual check for identity has been carried out;

(f)

the material is consistent with documented specifications;

(g)

each container is appropriately labelled and correctly identified;

(h)

required samples have been taken for testing and/or retention;

(i)

the material has passed all required quality control tests.

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

The records include the date of release by either Quality Control or an authorised, competent person.
531

There are written procedures for the internal labelling (including status labelling to indicate whether under test,
quarantined, passed for use or rejected), quarantine and storage of raw materials, packaging materials and other
materials, as appropriate.

532

Any special storage requirements (eg temperature) for individual materials are documented. Records are kept to
confirm that materials have been kept under appropriate storage conditions.

Master manufacturing formula, master batch records and master manufacturing processing instructions
533

Formally authorised master manufacturing formula and master manufacturing (or processing) instructions, that are
appropriate for the type of product being made and consistent with data submitted for product registration, exist for
each product and batch size to be manufactured. They may be combined in one document.

534

The master manufacturing formula and master manufacturing instructions are prepared, endorsed and dated by a
competent person delegated by management. A second authorised person checks, endorses and dates the instructions
where possible. They are kept up to date at all times and reviewed at specified intervals not exceeding three years.
Any amendments are checked by a second competent person.

535

The master manufacturing formula/master batch records include:

(a)

the name of the product, with a product reference code relating to its specification;

(b)

a description of the pharmaceutical form (eg liquid, powder, cream), strength or potency of the product, and
batch size;

(c)

a list of all raw materials to be used, with the amount of each (quantity per unit dose and the quantity per batch),
using the designated name and provision for entry of the manufacturers UIN;

(d)

a statement of the percentage excess, where a predetermined excess (overage) of any ingredient is used;

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KP80_F33

Master manufacturing formula, master batch records and master manufacturing processing instructions (cont)
Check
Point
No.

Checkpoint

Acceptable

(e)

provision for making any adjustments for potency, moisture etc; mention are made of any substance that may
disappear in the course of processing;

(f)

provision for entry of the expected final yield, with the acceptable limits and of relevant intermediate yields,
where applicable.

Minor
non
conformance

Major
non
conformance

Not
Audited

Where practicable, batch sizes are standardised.

536

The master manufacturing (or processing) instructions include:

(a)

a statement of the processing location and the principal equipment to be used;

(b)

the methods, or reference to the methods, to be used for preparing the critical equipment (eg cleaning,
assembling, calibrating, sterilising);

(c)

detailed stepwise processing instructions (eg checks on materials, pre-treatments, sequence for adding materials,
mixing times, temperatures) with provision to record relevant data, such as time, pH, temperature;

(d)

the instructions for any in-process controls, with their limits;

(e)

where necessary, the requirements for bulk storage of the products, including the container, labelling and special
storage conditions and/or time limits, where applicable;

(f)

any special precautions to be observed with regard to product quality and personal safety (eg scheduling to
prevent cross-contamination, clothing requirements, directions for dealing with spills, if relevant);

(g)

provision for operator initials or signatures at suitable stages;

(h)

a summary of all necessary quality control tests and analyses, and at what stage they are to be carried out.

Master packaging and labelling instructions

537

There are formally authorised master packaging and labelling instructions for each product pack size and type. These
may be combined with manufacturing records in one document.

538

The master packaging and labelling instructions are prepared, endorsed and dated by an authorised person. An
authorised second person checks, endorses and dates the instructions, where possible. Instructions are kept up to date
at all times and reviewed at intervals of no longer than three years. Any amendments are checked by an authorised
second person.

539

The master packaging and labelling instructions include, or have a reference to, the following:

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KP80_F33

Master packaging and labelling instructions (cont)

Check
Point
No.

Checkpoint

(a)

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

name of the product;

(b) description of its pharmaceutical form, and strength, where applicable;

(c)

the pack size, expressed in terms of the number, weight or volume of the product in the final container;

(d)

a complete list of all the packaging materials required for a standardised batch size and, where required, an
actual batch size, including quantities, sizes and types, with the code or reference number relating to the
specifications of each packaging material;

(e)

where appropriate, an example or reproduction of the relevant printed packaging materials or labels, or the
APVMA label approval number(s);

(f)

special precautions to be observed, including a careful examination of the area and equipment, in order to
ascertain the line clearance before operations begin; any relevant scheduling and/or special cleaning instructions;
and any relevant safety precautions;

(g)

a description of the packaging operation, including any significant subsidiary operations, and equipment to be
used;

(h)

details of in-process controls, with instructions for sampling and acceptance limits;

(i)

the approved shelf life;

(j)

provision for calculation of batch yield;

(k)

provision for label reconciliation.

Batch manufacturing/processing records

540

A batch manufacturing record is kept for each batch processed. It is based on the current, approved master
manufacturing formula/master batch record and manufacturing instructions and may be a photocopy of the master
documents or a specially designed computer print-out. The method of preparation of such records is designed to avoid
transcription errors. The record carries the number of the batch being manufactured. Each batch of product is
provided with a unique identifiable batch number, as specified in the Agvet Codes Regulations.

541

During processing, information is recorded at the time each action is taken and, after completion, the record is dated
and signed showing agreement by the person responsible for the processing operations. The information recorded
includes:
(a)

KP80_F33

dates and times of commencement of significant intermediate stages and of completion of production;

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KP80_F33

Batch manufacturing/processing records (cont)

Check
Point
No.

Checkpoint

Acceptable

(b)

name of the person responsible for each stage of production;

(c)

initials of the operator of each significant step of production and, where appropriate, of the person who checked
each of these operations (eg weighing);

(d)

the UIN, as well as the quantity of each starting material actually weighed (including the batch number and
amount of any recovered or reprocessed material added);

Minor
non
conformance

Major
non
conformance

Not
Audited

(e) a record to confirm that the equipment and work station are clear of previous products, documents or materials
not required for the planned process, and that equipment is clean and suitable for use;
(f)

any relevant processing operation or event and major equipment used;

(g)

a record of the in-process controls, the initials of the person(s) carrying them out, and the results obtained;

(h)

the final product yield, as well as yields obtained at pertinent stages of manufacture;

(i)

notes on special problems, including details, with signed authorisation, for any planned deviation from the
manufacturing formula and processing instructions and authorisation for processing to continue in the event of
unplanned deviations.

Batch packaging records

542

A batch packaging record is kept for each batch or part batch processed. It is based on the master packaging
instructions and may be a photocopy of the master documents or a specially designed computer print-out. The method
of preparation of such records is designed to avoid transcription errors. The record carries the batch number and the
quantity of bulk product to be packed, as well as the estimated quantity of finished product that will be obtained.

543

Before any packaging operation begins, there are recorded checks that the equipment and workstation are clear of
previous products, documents or materials not required for the planned packaging operations, and that equipment is
clean and suitable for use (line clearance).

544

The following information are entered at the time each action is taken and, after completion, the record is dated and
signed showing agreement by the person(s) responsible for the packaging operations:
(a)

the date and time of the packaging operation;

(b)

the name of the responsible person carrying out the packaging operation; and the initials of the operators of
significant steps;

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KP80_F33

Batch packaging records (cont)

Check
Point
No.

Checkpoint

Acceptable

(d)

a record to show that all packaging materials and labels have been assembled before starting and checked for
identity and conformity with the packaging instructions and that the labels carry, or are to be printed with, the
correct batch number and expiry date;

(e)

details of the packaging operations carried out, including references to equipment and the packaging lines used;

(f)

notes on any special problems or unusual events, including details with signed authorisation for any deviation
from the master packaging instructions;

(g)

the signature of the person responsible for the operation confirming that the operation has been carried out in
accordance with the packaging and labelling instructions;

(h)

where practicable, a sample of the label used, showing the added batch number and expiry date, and any other
overprinting, as well as samples of any other pre-printed packaging materials used;

(i)

the quantities and UINs/batch numbers of all printed packaging materials and bulk product issued, used,
destroyed or returned to stock and the quantities of obtained product;

(j)

results for batch yield from the bulk supplied to be packed and, unless otherwise justified, for reconciliation of
labels and pre-printed packaging materials. Where practicable, any part-batch packed are subject to yield and
reconciliation controls.

Minor
non
conformance

Major
non
conformance

Not
Audited

Where product is filled into unlabelled containers for later labelling, special precautions are taken to maintain the
identity of the product during storage.

Quality control sampling and testing

545

There are written procedures for sampling and testing as specified in Chapter 8 of the GMP Code

Release/rejection and distribution of finished product

546

Written release and rejection procedures are available for materials and products, and in particular for the release for
supply of the finished product by the authorised person(s) designated for the purpose.

547

Batch records show the name of the person responsible for releasing the product for supply, and confirm, by way of
that persons signature, that:
(a)

KP80_F33

all manufacturing documents have been reviewed;

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KP80_F33

Release/rejection and distribution of finished product (cont)

Check
Point
No.

Checkpoint

(b)

all entries are complete;

(c)

there are no unexplained or unresolved deviations;

(d)

the product meets all specifications;

(e)

a final packed item has been visually examined.

Acceptable

548

Where finished product has been rejected, the batch records include a note as to the reason and confirm that the batch
has been status-labelled and appropriately quarantined and/or disposed of.

549

Records are maintained of the distribution of each batch of a product, in order to facilitate a recall.

Minor
non
conformance

Major
non
conformance

Not
Audited

Complaints, recalls and returns

550

Records of complaints, recalls and returned products are retained for an appropriate period, to be defined by the
manufacturer.

Computer records
551

Where computer systems are used to store critical manufacturing information or control manufacturing processes,
records are maintained as required by Chapter 6 of the GMP Code.

Laboratory records
552

Records maintained in quality control laboratories meet the requirements of Chapter 8 of the GMP Code.

Validation records
553

Records are kept of all validation studies carried out. In addition to the raw data, the records include a technical
report, set out in report format, providing details of the rationale for the study, the methods used, when and by whom it
was carried out, the results and the conclusions.

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KP80_F33

Other records
Check
Point
No.

554

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

There are written procedures and records of actions taken or conclusions reached, where appropriate, for:
(a)

pest control (including details of any pest control program implemented, records of observations made as part of
that program and any casual sightings, and details of any corrective action taken);

(b)

general maintenance, cleaning and sanitisation (cleaning and sanitising instructions should include the name and
strength of any cleaning/sanitising agent used);

(c)

equipment installation and assembly, qualification and calibration (qualification and calibration records should
show tolerance limits);

(d)

equipment maintenance, cleaning and sanitisation (cleaning and sanitising instructions should include the name
and strength of any cleaning/sanitising agent used);

(e)

personnel matters, including medical checks, training, clothing and hygiene;

(f)

environmental monitoring (including temperature and other controlled-environment monitoring devices).

555

Clear operating procedures and, where appropriate, specific cleaning instructions, are available for major items of
manufacturing and test equipment.

556

Log books or equivalent records are kept for major or critical equipment, to record any validations, calibrations,
maintenance, or repair operations, including dates and the identity of people who carried out those operations.

557

Log books or equivalent records also record, in chronological order, the use and cleaning of major or critical
equipment and of the areas where the products have been processed.

Key observations and comments (Comment on both positive and negative aspects of Documentation and Records. Record evidence sighted and reviewed, such as
SOPs and records, particularly with respect to non-conformance) .

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CORE ELEMENT 6

KP80_F33

COMPUTER SYSTEMS

Manufacturing principles
Where, in any step of manufacture, a computer is used for any activity that may affect the quality, safety or efficacy of a product, then the computer system must be subject to
quality system management principles to ensure operational suitability.
The introduction of computer systems into any manufacturing process, including materials control, processing control, quality control and product distribution, must not
adversely affect product quality or quality assurance.

General
Check
Point
No.

Checkpoint

Acceptable

601

A written description of the system is available and kept up to date. It describes the objectives of the system and how
it interfaces with other systems and processes.

602

Before a system involving a computer is brought into use, it is thoroughly tested and shown to be capable of achieving
the intended outcomes. If a manual system is being replaced by a computer system, or the computer system is being
upgraded, both systems are run in parallel for a time as part of this testing and validation. The extent of validation
necessary will depend on a number of factors, including the intended outcomes, whether it is prospective or
retrospective and whether novel elements are incorporated.

603

If software has been commissioned specifically for the manufacturer, its development is documented at all stages and
each step evaluated by expert review against the written objectives. The stages to be documented include planning,
specification, programming, testing, installation and operational performance qualification.

604

If the software is off-the-shelf, but has been configured for the manufacturers use, then installation qualification and
operational qualification are undertaken. This includes a list of the values/fields/variables/parameters that have been
chosen, with detail of how this information is secured and made subject to change control and details of the tests for
security that were applied. The operational qualification shows how the system successfully handles instructions and
data.

605

If off the shelf software has been partly or fully customised, its development is treated as in 603 above.

606

If the software is off-the-shelf and has not been configured or customised for use, then it is precisely defined and
installation and performance qualification are carried out to demonstrate that user requirements have been satisfied.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Computer systems general (cont)

Check
Point
No.

Checkpoint

Acceptable

607

Alterations to a computer system are made only in accordance with a change control procedure, which include
provision for checking and approving the changes and, to the appropriate extent, performing operational and/or
performance qualification.

608

When outside agencies provide a computer service, there is a formal agreement that includes a clear statement of the
responsibilities of that outside agency.

609

A second authorised person verifies the entry of all critical data, such as master formulae, into a computer system.

610

The system is capable of providing printed copies of all stored data relevant to product quality. Printed matter
produced by computer peripherals is clearly legible.

611

A procedure is established to record and analyse errors and to enable corrective action to be taken.

612

The system records the identity of persons who enter or confirm critical data and is capable of creating a time-stamped
record of such entries or confirmations and of all amendments.

613

Data are entered only by authorised persons and there are methods of preventing unauthorised entry. There is a
defined procedure for the issue, alteration or cancellation of authority to enter and amend data.

614

If the computer system is used for batch release, the authority to release is clearly defined.

615

Records are backed up regularly and progressively, and the backup is retained at a secure and remote location until the
next backup is filed. Permanent archived electronic records are transferred to new media at regular intervals to avoid
loss.

616

There are contingency plans and recovery procedures for use in the event of a breakdown of the system. This may be
part of a broader disaster recovery plan.

Minor
non
conformance

Major
non
conformance

Not
Audited

Key observations and comments (Comment on both positive and negative aspects of Computer Systems. Record evidence sighted and reviewed, such as SOPs and
records, particularly with respect to non-conformance) .

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CORE ELEMENT 7

KP80_F33

PRODUCTION

Manufacturing principles
Veterinary chemical products must be manufactured to specifications in accordance with manufacturing information supplied as part of their application for registration and/or
any subsequent approved variations.
Production operations must follow documented procedures that have been clearly defined by the manufacturer.
Any critical manufacturing process and any change to that manufacturing process, must be validated and formally approved by an authorised person. Where a change in the
manufacturing process affects the registered specifications of the finished product, formal approval of such changes must be obtained from the registering authority before the
affected product is released for supply.

General
Check
Point
No.

Checkpoint

Acceptable

701

Each material used is consistent with documented specifications and the master manufacturing formula, and each step
of manufacture carried out (such as receipt and quarantine, quality assurance of raw materials, dispensing, processing,
packaging, labelling and quality control procedures) is in accordance with documented procedures and the master
manufacturing instructions.

702

For each batch of product made, records are kept of all materials used and of all critical steps and control procedures
carried out.

703

All surfaces which come into contact with raw materials, intermediate materials and finished product are maintained at
an appropriate level of cleanliness at all stages of manufacture.

704

The manufacturing process are periodically monitored at all critical stages to ensure both the reliability of the
manufacturing process and product quality, including microbial testing if relevant.

705

The identity and where relevant, the status of every material, including waste, is clearly shown on the outside of its
container.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Materials control (including storage)

(a) General
Check
Point
No.

Checkpoint

Acceptable

706

Records are kept of all incoming materials received in the store (whether raw materials, intermediate or bulk products
or finished products).

707

All incoming raw materials and packaging materials are checked to ensure that the consignment corresponds with the
order. Containers are cleaned where necessary and clearly labelled.

708

Damage to containers and any other problem that might adversely affect the quality of a material is investigated,
recorded and reported to Quality Control.

709

Incoming raw materials and finished products are physically or administratively quarantined immediately after receipt
or processing until they have been released for use or distribution. If physically quarantined, designated quarantine
areas are available for this purpose.

710

Materials received as intermediate or bulk products are handled on receipt as though they were raw materials.

711

All materials and products are stored under conditions that will minimise deterioration and are stored in an orderly
fashion to permit batch segregation and stock rotation.

(b)

Minor
non
conformance

Major
non
conformance

Not
Audited

Receipt, storage and quality assurance of raw materials

712

Raw materials are purchased only from approved suppliers named in the relevant specification.

713

Each delivery of starting material is given a unique identifying number (UIN). If one delivery of material is made up
of different batches, each batch is considered as separate for sampling, testing and release and given a separate UIN.

714

Raw materials are appropriately labelled on receipt with at least the following information:
(a)

the designated name of the starting material and the internal reference code where applicable (each starting
material is identified by and used under one name only);

(b)

a number (UIN) given at receipt;

(c)

the status of the contents (eg quarantined, on test, released, rejected);

(d)

where appropriate, an expiry date or a date beyond which retesting is necessary.

Note that when computerised storage systems are used, all the above information need not necessarily be specified
in text on the label.

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(b)

Receipt, storage and quality assurance of raw materials (cont)

Check
Point
No.

Checkpoint

Acceptable

715

As soon as possible after receipt, each starting material is assessed, in accordance with a written procedure, for its
suitability for use, as set out in Chapter 5 of the GMP Code.

716

A stock rotation system is implemented to ensure that raw materials are used by the nominated expiry/retest date.

717

There are appropriate procedures or measures to ensure that the identity and status of all containers of raw materials
can be recognised from their labelling at all times. Containers from which samples have been drawn are identified.

718

The handling and treatment of animals used for production and testing purposes complies with all the relevant animal
welfare guidelines. Animals used for production purposes or for testing components, materials or products are, where
appropriate, be quarantined before use. They are maintained and controlled and where necessary subjected to testing,
to assure that they meet specifications and are suitable for the intended use. They are identified, and adequate records
are maintained showing the history of their use.

(c)

KP80_F33

Minor
non
conformance

Major
non
conformance

Not
Audited

Receipt, storage and quality assurance of packaging materials

719

Upon receipt, packaging materials, including printed labels, are quarantined until checked against specifications and
approved.

720

Each delivery or batch of printed or primary packaging material received is given a specific reference number or
identification mark.

721

Pre-printed labels are not overprinted with a different name, dosage, formula or strength of the product.

722

Labelling materials are only issued for use by authorised personnel following an approved and documented procedure.

723

Stocks of labels and pre-printed packaging materials are checked annually and outdated or obsolete material
destroyed. This disposal is recorded.

Cross-contamination control
724

Cross-contamination is minimised by appropriate technical or organisational measures, which may include:

(a)

KP80_F33

production in physically segregated areas (required for products such as live vaccines, live bacterial
preparations and some other biologicals, as well as penicillins and other highly sensitising materials);

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KP80_F33

Cross-contamination control (cont)

Check
Point
No.

725

Checkpoint

Acceptable

(b)

adequately isolating plant and/or equipment by a suitable distance;

(c)

production on a campaign basis, followed by appropriate and validated cleaning, or scheduling the manufacture
of different products in an appropriate sequence;

(d)

providing effective air/dust extraction systems and/or airlocks;

(e)

keeping lids on mixing vessels;

(f)

avoiding recirculation or re-entry of untreated or insufficiently treated air;

(g)

keeping protective clothing inside areas where products with special risk of cross-contamination are processed;

(h)

using effective and validated cleaning/decontamination procedures, and using cleaning status labels;

(i)

using closed production systems.

Minor
non
conformance

Major
non
conformance

Not
Audited

Where cross-contamination has the potential to cause a hazard to the treated animal, the effectiveness of crosscontamination control measures is monitored periodically according to set procedures.

Process validation
726

Critical steps in the manufacture of each product or product group are validated with supporting data. The extent and
method of validation/revalidation are appropriate for the manufacturing method and the type of product and its use.

727

When any new manufacturing formula, method of preparation or significant change is adopted, steps are taken to
demonstrate its suitability for routine processing. The defined process, using the materials and equipment specified, is
shown to yield a product consistently of the required quality.

728

Validation studies are conducted in accordance with defined procedures. They include the most challenging of any
permitted ranges in process variables. Results and conclusions are recorded as technical reports.

Production procedure
(a)

Dispensing of raw materials

729

The raw materials used for a particular product conform to the master manufacturing formula. No substitution is
allowed unless the change is authorised in writing by an authorised person.

730

Only raw materials that have been released for use and which are within their shelf life, are used.

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(a)

Dispensing of raw materials (cont)

Check
Point
No.

Checkpoint

Acceptable

731

Raw materials are dispensed only by designated persons, following a written procedure. Correct materials are
accurately weighed or measured into clean and properly labelled containers.

732

The dispensing operation is supervised or verified to the extent necessary to ensure the accuracy of the weight/volume
and the identity of the materials and all checks are recorded.

733

Materials dispensed for each batch are kept together, isolated from other materials and be conspicuously labelled with
the product batch number.

(b)

KP80_F33

Minor
non
conformance

Major
non
conformance

Not
Audited

Processing operations

734

Before any processing operation is started, steps are taken to ensure that the work area and equipment are clean,
suitable for use and free from any raw materials, products, product residues or documents not required for the current
operation.

735

The product is manufactured in full accordance with authorised batch manufacturing instructions. Any variation from
those instructions is authorised in writing by an authorised person.

736

Intermediate preparations, such as solutions used for pH adjustments or coating solutions, are prepared following the
same system of master formulae and processing instructions and their batch numbers are carried forward onto the
documents for the finished products in which they are used.

737

Where operations on different products are carried out simultaneously or consecutively in the same room, and where
this is a product quality or safety issue, there are measures in place to prevent mix-up and/or cross-contamination.

738

At every stage of processing, products and materials are protected from microbial and other contamination.

739

When working with dry materials and products, precautions are taken to minimise the generation and dissemination of
dust. This applies particularly to the handling of highly active or sensitising materials.

740

At all times during processing, all materials, bulk containers, major items of equipment and, where appropriate, rooms
used, are labelled or otherwise identified with the name of the product or material being processed, its strength (where
applicable) and batch number. Where applicable, the label also mentions the stage of production.

741

Labels applied to containers, equipment or premises are clear, legible, easily understood and in the manufacturers
agreed format. Colours may be used in association with wording to indicate status.

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(b)

Processing operations (cont)

Check
Point
No.

Checkpoint

Acceptable

742

Checks are carried out to ensure that transfer lines and other pieces of equipment used for the transportation of
products from one area to another are clean before use and are connected in a correct manner.

743

As far as possible, deviations from standard procedures are avoided. Where deviations occur, they are approved in
writing by an authorised person.

744

The production of incompatible products is avoided in areas and equipment destined for the production of veterinary
chemical products, unless precautions are taken to ensure the integrity of these veterinary chemical products.

745

All intermediate yields and the final product yield are checked and quantities reconciled against the theoretical or
expected values by a competent person. Any discrepancy that exceeds acceptable limits is recorded on the batch
records and investigated, and the batch quarantined until its status has been determined.

(c)

Minor
non
conformance

Major
non
conformance

Not
Audited

Intermediate and bulk products

746

Intermediate and finished products awaiting release by Quality Control are segregated physically, or by an equivalent
computer system, from other stock.

747

Intermediate and bulk products are stored under appropriate conditions that are clearly defined and documented.

748

Materials are transported between premises or buildings in a manner that ensures the integrity and status of the
material.

749

Delays in completion of the manufacturing process are kept to a minimum. The maximum holding time for
intermediate and bulk materials is clearly defined and justified.

(d)

KP80_F33

Process water

750

The quality of water required (potable or processed) is specified and consistent with approved registration details.

751

Where water is treated for use as an ingredient, a specification for this process water is developed, based on sound
physical, chemical and microbiological principles. Raw water is purified before use to meet this specification.

752

Where process water is used, a water quality manual is prepared. This document may be part of the manufacturers
quality manual and should include:

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(d)

KP80_F33

Process water (cont)

Check
Point
No.

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

(a) a drawing of the purification, storage and (where applicable) reticulation system, showing all pipelines, valves,
sample points, breather points, drain points, couplings, instrumentation, pipe slopes, flow rates and velocities of
water flow;
(b) both a brief description of and a full specification for each element in the system, including manufacturers
recommended flow rates;
(c) standard procedures for use, including start-up, shutdown, backwashing, regeneration, sanitising and filter
maintenance and testing;
(d) a log of system changes, routine and non-routine maintenance (unless routine maintenance is logged elsewhere
and the log is readily available), investigations, corrective action and validation studies;
(e) chemical and microbiological specifications, including resample, action and shutdown limits;
(f)

sampling instructions and testing procedures, including validation of procedures;

(g) results of tests, including graphical presentations;

(h) the positions of persons responsible for the operation and maintenance of the system and their deputies;
(i)

periodic reviews, conducted at least once per year.

753

Process water is tested at a frequency consistent with the history of successful control. Sampling procedures include
worst case sample points and production conditions. The sample size tested is sufficient to demonstrate process
control.

754

Microorganisms recovered from total counts are occasionally separately identified. Atypical results are investigated.

Primary (filling) and secondary packaging operations

755

Programs for packaging operations are devised to minimise the risk of cross-contamination, mix-ups or substitutions.
Different products are not packaged in close proximity unless there is physical segregation or the distance is great
enough to avoid a mix-up.

756

Before packaging operations are begun, a line clearance is undertaken to ensure that the work area, packaging lines,
printing machines and other equipment are clean and free from any products, materials or documents previously used,
if these are not required for the current operation.

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KP80_F33

Primary (filling) and secondary packaging operations (cont)

Check
Point
No.

Checkpoint

Acceptable

757

The name and batch number of the product being handled are displayed at each packaging station or line.

758

All products and packaging materials to be used are checked on delivery to the packaging department for quantity,
identity and conformity with the packaging instructions.

759

Containers are clean before filling. Attention is given to avoiding, and if necessary removing, any contaminants such
as glass fragments and metal particles.

760

Filling and sealing are followed as quickly as possible by labelling. Where this is not the case, appropriate procedures
are applied to ensure that no mix-ups or mislabelling occur.

761

The correct printing of code numbers or expiry dates, etc, done either separately or in the course of the packaging, is
checked and recorded. Printing by hand is re-checked at regular intervals.

762

Special care is taken when using cut labels and when over-printing takes place off-line.

763

Printed and embossed information on packaging materials is distinct and resistant to fading or erasing.

764

Checks are made to ensure that any electronic code readers, label counters or similar devices are operating correctly.

765

On-line control of the product during packaging includes checking at least the following:
(a)

general appearance of the packages;

(b)

whether the packages are complete;

(c)

whether the correct products and packaging materials are used;

(d)

whether any over-printing, such as batch numbering and expiry dating, is correct;

(e)

correct functioning of line monitors.

Minor
non
conformance

Major
non
conformance

Not
Audited

Samples taken away from the packaging line are not returned.
766

Products that have been involved in an unusual event (eg a mid-process breakdown in production or storage
conditions) are only reintroduced into the process after special inspection, investigation and approval by authorised
personnel. Detailed records are kept of this operation.

767

On completion of the packaging operation, yields are determined and reconciliation conducted. Acceptable limits are
established. Any significant or unusual discrepancy is investigated and satisfactorily accounted for before release.

768

Upon completion of a packaging operation, any unused batch-coded packaging materials is destroyed and the
destruction recorded. Unused printed material is re-inspected before being returned to stock.

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KP80_F33

Release of finished products

Check
Point
No.

Checkpoint

Acceptable

769

Finished products are held in quarantine, under conditions established by the manufacturer, until their final release.

770

All product batches are sampled for quality control and are not released for supply until all specified tests are
completed.

771

After release, finished products still under the control of the manufacturer, are stored under conditions consistent with
the approved product label.

Minor
non
conformance

Major
non
conformance

Not
Audited

Residual, rejected, recovered and returned materials

772

Product residues are not be incorporated into subsequent batches of product on a routine basis, except where this is
provided for in the master formula or processing instructions and where limits are prescribed for the proportion of
residue. In addition, a standard operating procedure should specify at least:
(a)

limits on the age and total quality of residue that may be accumulated;

(b)

limits on the number of batches of residue that may be incorporated in a single batch of product;

(c)

limits on the total quantity or proportion of residue that may be incorporated in a single batch of product;

(d)

a procedure for use and/or disposal that will facilitate overall reconciliation;

(e)

any necessary testing or approval.

773

Rejected materials and products are clearly marked as such and stored separately in clearly identified restricted
(quarantine) areas. They are either returned to the suppliers or, where appropriate, reprocessed or destroyed. Action
taken is approved and recorded by authorised personnel.

774

Recovery of all or part of earlier batches (that conform to the required quality), by incorporation into a batch of the
same product at a defined stage of manufacture, is authorised beforehand. This recovery is carried out in accordance
with a defined procedure after evaluation of the risks involved, including any possible effect on shelf life. The
recovery is recorded.

775

Finished product returned from the manufacturers own stores or warehouse (eg because of soiled or damaged labels
or outer packaging) is only relabelled, or bulked for repacking when there is no risk to product quality and the
operation is specifically authorised and documented. If such a product is relabelled, the operation is regarded as a
formal packaging operation. If bulked, the operation is regarded as a formal processing operation.

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KP80_F33

Residual, rejected, recovered and returned materials (cont)

Check
Point
No.

Checkpoint

Acceptable

776

Products returned from the market, which have left the control of the manufacturer, are destroyed, unless without
doubt their quality is satisfactory. They are considered for re-sale, relabelling or recovery with a subsequent batch,
only after they have been critically assessed by Quality Control in accordance with a written procedure. The nature of
the product, any special storage conditions that it requires, its condition and history, and the time elapsed since it was
issued are all taken into account in this assessment. There is no adverse effect on the shelf life of the product batch.
Where any doubt arises over the quality of the product, it is considered un-suitable for re-issue or re-use, although
basic chemical reprocessing to recover active ingredients may be possible. Any action taken is appropriately recorded.

777

The need for additional testing of any finished product that has been reprocessed, or into which a recovered product
has been incorporated, is considered by Quality Control.

778

A suffix or batch number is used to distinguish any bulked or re-labelled material.

Minor
non
conformance

Major
non
conformance

Not
Audited

Key observations and comments (Comment on both positive and negative aspects of Production Procedures. Record evidence sighted and reviewed, such as SOPs,
records and observations, particularly with respect to non-conformance) .

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CORE ELEMENT 8

KP80_F33

QUALITY CONTROL

Manufacturing principles
Manufacturers of veterinary chemical products must have in place an effective quality control system which is designed to ensure that, before products are released from
manufacture for supply, they meet specifications and have been manufactured in accordance with the manufacturers documented procedures.
The person responsible for quality control must be sufficiently independent of other aspects of the manufacturing operation to allow effective implementation of the quality
control function.
Manufacturers must ensure that analytical laboratories and animal testing facilities used in a step of manufacture follow the principles of good laboratory practice.

General
Check
Point
No.

Checkpoint

Acceptable

801

The manufacturer has an identifiable quality control function. This function is independent from other functions and
under the authority of a person (with appropriate qualifications and experience), who has access to one or more control
laboratories. Adequate resources are available to ensure that all the quality control arrangements are effectively and
reliably carried out.

802

Where practicable, a quality control laboratory is available and adequately staffed and equipped for the performance of
all quality control tests required before, during and after manufacture. Where there is no in-house facility, or the inhouse facility does not have the capability of doing all required quality tests, satisfactory alternative arrangements for
the required quality control testing exist.

803

The principal duties of the head of Quality Control are summarised in Chapter 2 (clause 210) of the GMP Code.
Quality Control also has other duties, which may include:
(a)

establishing adequate quality control specifications for all materials at all stages of manufacture and for the
finished product;

(b)

establishing, documenting, validating and implementing all quality control test procedures;

(c)

assessing and releasing/rejecting starting and intermediate materials for each batch;

(d)

assessing and releasing/rejecting each batch of finished product for supply;

(e)

keeping reference/retention samples of materials and products;

(f)

ensuring the correct labelling of containers of materials and products;

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Minor
non
conformance

Major
non
conformance

Not
Audited

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GMP Audit Checklist for MANUFACTURERS

KP80_F33

Quality control general (cont)

Check
Point
No.

Checkpoint

Acceptable

(g)

monitoring the suitability of packaging materials;

(h)

monitoring the stability of the products, the suitability of expiry dates and product storage conditions;

(i)

participating in the investigation of complaints related to the quality of the product;

(j)

monitoring environmental control of quality control laboratories and test animal houses as appropriate;

(k)

reviewing trends in analytical results or yields;

(l)

establishing or approving procedures for animal quarantine, animal testing and the recovery of biological
material from animals for use in analysis, testing or production.

Minor
non
conformance

Major
non
conformance

Not
Audited

All these operations are carried out in accordance with written procedures and recorded.
804

Analytical laboratories and animal testing facilities follow the principles of good laboratory practices (GLP). Written
procedures are established for at least the following:
(a)

cleaning of quality control areas and equipment;

(b)

preparation of materials and reagents;

(c)

maintenance of reference substances;

(d)

calibration and maintenance of quality control equipment;

(e)

dealing with out-of-specification results;

(f)

reviewing analytical performance.

805

Quality Control personnel have access to production areas for sampling and investigation as appropriate. They are
empowered to take samples from any stage of the manufacturing process or from finished products at any time, and
take and retain samples, using documented procedures, as required in clauses 813 823.

806

Quality Control receives prompt information on any proposed changes or modification to material sourcing,
specification, production procedures or written instructions.

807

Where any quality control testing is contracted to an external laboratory:

(a)

the records of this testing indicate the source of the test results (see Chapter 9 of the GMP Code);

(b)

the laboratory complies with AS ISO/IEC 17025, or with any subsequent amendment;

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KP80_F33

Quality control general (cont)

Check
Point
No.

Checkpoint

(c)
808

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

the laboratory, if located in Australia, is appropriately licensed by APVMA to test veterinary chemical products
in the manner required.

Animals used for testing components and products are handled in the same way as those used in the manufacturing
process (see clause 718, Chapter 7 of the GMP Code).

Documentation
809

Laboratory documentation follows the general principles given in Chapter 5 Documentation of the GMP Code. The
following information is either prepared by, or readily available to, Quality Control:
(a)

specifications;

(b) sampling procedures;

(c)

testing procedures and records (including analytical worksheets and/or laboratory notebooks);

(d)

analytical reports and/or certificates;

(e)

data from environmental monitoring, where required;

(f)

validation records of test methods, where applicable;

(g)

procedures for and records of, the calibration of instruments and maintenance of equipment.

810

Any quality control documentation relating to a batch record is retained for the period defined in clauses 517-522, in
Chapter 5 of the GMP Code.

811

Records of analytical test results, yields and environmental controls are kept in a manner permitting trend evaluation.

812

In addition to the information that is part of the batch record, other original data such as laboratory notebooks and/or
records are retained and readily available.

Sampling
(a)
813

Sampling plans
Sampling plans for starting materials (excluding packaging materials):
(a)* differentiate between certified, approved and other suppliers, including unknown suppliers, as appropriate;

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(a)

KP80_F33

Sampling plans (cont)

Check
Point
No.

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

(b) differentiate between starting materials that do not bear a manufacturers batch number and those that do;
(c)* take account of the nature of each material, for example its potency and whether its place and method of
manufacture may ensure against mix-up or even make mix-up impossible;
(d) take account of the intended use of the material (eg whether it is for injection);
(e)* differentiate between materials that may be expected to vary from container to container (eg by separation or
moisture uptake) and those that may not;
(f)* prescribe the action to be taken where a delivery from a certified or approved supplier has failed;
(g) prescribe an increased sampling rate for damaged containers or for lots that do not appear to be homogenous;
(h) specify the extent of pooling of samples destined for tests other than identification;
(i)
814

(b)
815

require the sampling officer or analyst to initially examine each sample for homogeneity, evidence of
deterioration or other visible defect.

Sampling plans for packaging materials should take into account:

(a)

the items shown as (*) listed in Clause 813 for starting materials;

(b)

the need to check the identity of each container or reel of labels and pre-printed packaging materials;

(c)

the number of samples needed to reach a valid decision to approve or reject a delivery in relation to qualityrelated defects.

Sampling Procedures
Samples are taken in accordance with approved written procedures that describe:
(a)

the method of sampling;

(b)

the equipment to be used;

(c)

the amount of the sample to be taken;

(d)

instructions for any required subdivision or pooling of samples;

(e)

the type and condition of the sample container to be used;

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(b)

Sampling Procedures (cont)

Check
Point
No.

Checkpoint

Acceptable

(f)

the identification of containers sampled;

(g)

any special precautions to be observed, especially with regard to the sampling of sterile or noxious materials;

(h)

the storage conditions;

(i)

instructions for the cleaning and storage of sampling equipment.

816

The sampling procedure is justified, taking into consideration the nature of the material or the method of manufacture
of the product being sampled.

817

Sample containers bear a label indicating the contents, the batch number, the date of sampling and the containers from
which samples have been drawn.

818

All samples taken for quality control purposes are taken by Quality Control personnel, except samples for in-process
control, which may be taken by authorised production staff.

819

All the in-process controls, including those made in the production area by production personnel, are performed
according to methods approved by Quality Control and the results are recorded.

(c)
820

KP80_F33

Minor
non
conformance

Major
non
conformance

Not
Audited

Retention samples
Quality Control take and retain samples of:
(a)

at least each batch of active starting material;

(b)

each batch of finished product.

821

Retention samples of materials and products are of a size sufficient to permit at least a full re-examination. In the case
of active raw materials, the quantity taken is at least twice the quantity required to establish identity and purity. In the
case of finished products, the number of units retained will depend on the product but are adequate to permit reexamination at a suitable time and investigation of possible complaints.

822

Retention samples from each batch of finished products are retained for the period specified in the Agvet Code
Regulations (see Chapter 5; Records of the GMP Code). Where practicable, these samples are kept in their final
packaging. Where the finished product samples are not stored in their final packaging, the packaging chosen is of the
same materials as the manufactured product. Retention samples are stored under the recommended conditions.

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(c)

Retention samples (cont)

Check
Point
No.

823

KP80_F33

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Samples of starting materials (other than solvents, gases and water) are retained for at least two years after the release
of the product, if their stability allows. (Note: This period may be shortened if their shelf life, as mentioned in the
relevant specification, is shorter).

Product release
824

Products are released in accordance with the procedures specified in Chapter 5 in the GMP Code.

Key observations and comments (Comment on both positive and negative aspects of Quality Control. Record evidence sighted and reviewed, such as SOPs and
records, observations, etc, particularly with respect to non-conformance) .

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CORE ELEMENT 9

KP80_F33

CONTRACT MANUFACTURE

Manufacturing principles
Where all or part of the manufacture of a veterinary chemical product is contracted to another party, the licensed manufacturer(s) must ensure that, before manufacture
commences, both parties have signed a written GMP Agreement that clearly specifies each partys responsibility in relation to every aspect of the manufacturing process,
assurance of product quality and consistency with product registration particulars.
Arrangements for contracted steps of manufacture must not compromise the quality of the product.
Where a contractor is authorised to manufacture under the licence of another manufacturer, the licence holder must exert direct control and oversight of the quality
management of the contracted step.

General
Check
Point
No.

Checkpoint

Acceptable

901

Contracted manufacture may involve the entire production and packaging processes, or steps such as tablet coating,
packaging, labelling, sterilisation, analysis or testing and release for supply.

902

When the manufacturer (contract giver) contracts all or some of the steps of manufacture to another manufacturer
(contract acceptor), a written agreement (usually referred to as a GMP Agreement or Specification of GMP
Responsibilities) is drawn up that clearly defines the steps of manufacture, or scope of any analytical work, to be
carried out. It also defines the GMP responsibilities of each party for each aspect of the work. All GMP Agreements
are kept up to date.

903

Contract manufacture is undertaken only by a manufacturer who is the holder of an APVMA Manufacturers Licence,
unless the work undertaken by the contract acceptor falls within the scope of the contract givers licence as specified
in Agricultural and Veterinary Chemicals Code Regulations 1995, cited below.

Minor
non
conformance

Major
non
conformance

Not
Audited

Regulation 59A:
A person who performs only a single step in the manufacture of a product is an exempt person in relation to the manufacture if:
(a)
the step consists only of:
(i) packaging or labelling, or both packaging and labelling, the product; or
(ii) analysing or testing the product; and
(b)
either:
(i) the licence that authorises the manufacture of the product (being a licence held by another person) permits the first-mentioned person to perform the step for the product; or
(ii) the step consists only of applying a label that contains only a name and address, or the registration number of the product, or both, to a package, or packages of the product.

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KP80_F33

The GMP Agreement

Check
Point
No.

Checkpoint

Acceptable

904

The GMP Agreement clearly describes who is responsible for purchasing materials, testing and releasing materials and
undertaking production and quality controls, including in-process controls, sampling, analysis, release for supply and
the storage of records and retention samples.

905

The Agreement permits the contract giver, an agreed third party or an APVMA-authorised GMP auditor to visit the
facilities of the contract acceptor for auditing purposes. The agreement also requires the contract giver to provide, for
this purpose, access to details of relevant analytical methodology and validation studies, or manufacturing procedures,
quality control tests and manufacturing records.

906

Technical aspects of the contract are drawn up by competent persons with knowledge of veterinary chemical
manufacture, analysis and/or GMP, as is appropriate. All arrangements for manufacture and analysis are in accordance
with the appropriate product registration and be agreed to by both parties.

Minor
non
conformance

Major
non
conformance

Not
Audited

The contract giver

907

Only APVMA-authorised manufacturers are selected to carry out the specified steps of contract manufacture.

908

The contract giver provides the contract acceptor with all the information necessary to carry out the contracted
operations correctly in accordance with registered particulars and any other legal requirements. The contract giver
also ensures that the contract acceptor is fully aware of any aspects of the product or the work which might pose a
hazard to the contract acceptors premises, equipment, personnel, or other materials or products used or made on the
premises.

909

The contract giver accepts responsibility for:

(a)

assessing the competence of the contract acceptor to successfully carry out the required work;

(b)

ensuring that all arrangements for steps of manufacture, including any proposed changes of a technical nature,
are in accordance with the registration particulars for the product concerned;

(c)

ensuring that all materials or processed products delivered to them by the contract acceptor comply with their
specifications, and that they have been released by a competent authorised person.

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KP80_F33

The contract acceptor

Check
Point
No.

Checkpoint

Acceptable

910

The contract acceptor makes sure, by quality assurance measures or by certification from another licensed
manufacturer, that all raw materials received from any source meet relevant specifications and that all work in relation
to those products or materials is carried out in compliance with requirements of this Code of GMP.

911

The contract acceptor refrains from any activity that may adversely affect the quality of the product manufactured
and/or analysed for the contract giver.

912

Where the contract acceptor is an analytical laboratory, the contract acceptor makes available to the contract giver
details of all analytical procedures carried out on the contract givers materials, as well as details of any relevant
validation studies carried out on those procedures. Alternatively, where the contract acceptor considers an analytical
method to be confidential property, that method and its validation are available to the APVMA.

913

The contract acceptor makes available to the contract giver details of all manufacturing procedures and any quality
control tests carried out on the contract givers behalf, as well as copies of relevant manufacturing records.

914

The contract acceptor does not pass to a third party any of the work entrusted to them under the contract without the
prior evaluation and written consent of the contract giver.

915

Arrangements made between the contract acceptor and any third party are subject to a GMP Agreement between either
the original contract giver or the contract acceptor and the third party. Those arrangements ensure that relevant
manufacturing and analytical information is made available to the third party in the same way as between the original
contract giver and contract acceptor. The third party holds an APVMA Manufacturers Licence, unless exempted under
the Agricultural and Veterinary Chemicals Code Regulations 1995 or otherwise authorised by the APVMA, as in the
case of overseas manufacturers, and accepts the same responsibilities as the contract acceptor.

916

Manufacturing, analytical and distribution records, and retention samples are kept as specified in the GMP Agreement
and in accordance with the Agricultural and Veterinary Chemical Codes Regulations 1995 (see also Chapter 5
Records of the GMP Code).

917

The contract acceptor has adequate premises and equipment, knowledge and experience, quality management system
and competent personnel to satisfactorily carry out the work ordered by the contract giver.

Minor
non
conformance

Major
non
conformance

Not
Audited

Inspection of contract manufacturers

918

918 Audits of contract manufacturers by the contract giver or an agreed third party are carried out to ensure that work
is carried out to requirements in accordance with GMP. The depth and frequency of inspections are determined on a
risk management basis.

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KP80_F33

Key observations and comments (Comment on both positive and negative aspects of Contract Manufacture. Record evidence sighted and reviewed, such as SOPs.
GMP contracts and records, particularly with respect to non-conformance).

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CORE ELEMENT 10

KP80_F33

INTERNAL AUDITS

Manufacturing principle
Manufacturers of veterinary chemical products must regularly and systematically carry out internal audits of all aspects of their manufacturing operations, as well as of
their quality assurance program, in order to monitor compliance with their authorised procedures, standards and requirements and ensure product quality. Steps must be
taken to implement any necessary corrective and preventive action identified by those internal audits and to assess the outcomes.

General
Check
Point
No.

Checkpoint

Acceptable

1001

A program of planned and documented internal audits (self-inspections) is in place to regularly and systematically
assess all aspects of manufacture and quality control for compliance with GMP and to assess the effectiveness of the
quality assurance system. Those audits cover all aspects of manufacture. The frequency and scope of audits takes into
consideration the status and importance of the areas to be inspected, as well as the results of previous audits.

1002

Internal audits are conducted by staff who have been trained and are competent in internal audit procedures, and where
practicable, staff who do not have direct responsibility for the processes being audited. Alternatively, independent
external auditors are used.

1003

Where the need for corrective action has been identified, steps are taken to address any observed deviations from the
documented quality system and manufacturing procedures. Corrective and preventive actions are monitored for
effectiveness and modified if necessary. Documented procedures are amended if there is an identified need to do so.

1004

Records are kept of all internal audits undertaken, the outcomes of those audits, details of any corrective and
preventive action taken and the effectiveness of such action.

Minor
non
conformance

Major
non
conformance

Not
Audited

Key observations and comments (Comment on both positive and negative aspects of Contract Manufacture. Record evidence sighted and reviewed, such as SOPs
and records, particularly with respect to non-conformance) .

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CORE ELEMENT 11

KP80_F33

COMPLAINTS AND PRODUCT RECALLS

Manufacturing principles
Manufacturers of veterinary chemical products must have in place a system of handling complaints regarding products they have manufactured or otherwise handled on the
licensed premises. There must be a documented system of recording, investigating and, where appropriate, acting upon all complaints that may be related to product quality.
Manufacturers must also have in place a documented and effective procedure for recalling from the marketplace product that is known to be defective, or is suspected of being
defective.

Complaints
Check
Point
No.

Checkpoint

Acceptable

1101

There are documented procedures for the handling of all complaints, recalls and returned product.

11023

There is in place a documented procedure for receiving, recording, reviewing and, where appropriate, acting upon all
quality-related complaints received about veterinary chemical products manufactured or handled on the premises.
The procedure includes the need to consider a recall in the event of a complaint concerning a possible product defect.

1103

Records are kept of all complaints received, investigations carried out and their outcomes and any corrective action
taken to resolve the complaint and prevent the problem happening again.

1104

All complaints related to product quality are registered in a complaints register.

1105

Records should also be kept of all product returned for other reasons, the reason for the return (eg out of date product),
and its disposal. Records are also kept of any required corrective action.

1106

Responsibility for handling complaints related to product quality and for deciding the measures to be taken is
delegated to a specified member or group of staff, who are given adequate resources to carry out the task. If this
person is not the person responsible for quality, the latter are made aware of any such complaint or investigation
involving products manufactured or handled on the premises.

1107

The complaints procedure incorporates the APVMAs requirements for adverse experience reporting.

Minor
non
conformance

Major
non
conformance

Not
Audited

Suspected product defects

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Check
Point
No.

Checkpoint

KP80_F33
Acceptable

1108

If a product defect is discovered or suspected in a batch, other batches are checked in order to determine whether they
also might be affected. Attention is paid to other batches that may contain reworks of the defective batch.

1109

Complaints records are reviewed regularly for any indication of specific or recurring problems requiring attention and
possibly the recall of products.

Minor
non
conformance

Major
non
conformance

Not
Audited

Recalls
1101

The APVMA is notified if a manufacturer is considering recall action following possibly faulty manufacture, product
deterioration, or any other serious quality problem with a product. The competent authorities of all countries to which
defective products may have been distributed are also notified.

1100

There is a written procedure for the initiation and management of any recall activity, which is aligned with the
APVMAs guidelines for the recall of agricultural and veterinary chemical products and the requirements of the Trade
Practices Act. Procedures are regularly checked and updated when necessary.

1112

Responsibility for execution and co-ordination of recalls is delegated to a specific member or group of staff, who are
given adequate resources to handle all aspects of the recalls with the appropriate degree of urgency. This responsible
person is independent of the sales and marketing organisation. If this person is not the person responsible for quality,
the latter is made aware of any recall operation.

1103

Recall operations are capable of being initiated promptly and at any time, including outside normal working hours.
The recalls co-ordinator maintains a regularly updated list of emergency contact numbers, including after-hours
contact details.

1114

Distribution records are readily available to the person(s) responsible for recalls, and should contain sufficient
information on directly supplied customers, including those for exported products.

1115

Recalled products are identified and stored separately in a secure area while awaiting a decision on their fate.

1116

The progress of a recall is recorded and a final report issued, including reconciliation between the delivered and
recovered quantities of products.

1117

Records are kept of all recalls initiated (including internal dummy runs), all action taken, as well as of details of all
product returned as a result of recalls and its disposal. Records are in accordance with the APVMAs guidelines for the
recall of agricultural and veterinary chemical products.

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KP80_F33

Recalls (cont)
Check
Point
No.

1118

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

The effectiveness of the recalls procedure is evaluated from time to time by means of internal dummy runs and the
procedure revised if necessary. The outcome of these dummy runs is recorded, together with details of any
corrective action considered necessary.

Key observations and comments (Comment on both positive and negative aspects of Complaints and Product Recalls. Record evidence sighted and reviewed, such
as SOPs, records, etc, particularly with respect to non-conformance) .

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ANNEX 1

KP80_F33

STERILE PRODUCTS

Manufacturing principles
Veterinary chemical products that are required to be, or are represented as being sterile, must be manufactured:
in separate, controlled areas in the premises that have
- high standards of hygiene
- a system of controlling particulate contaminants appropriate to the class of veterinary chemical product being manufactured
with special care and attention to detail
in accordance with procedures established and validated by the manufacturer.
The manufacturer must establish procedures and have equipment available (or in the case of bioburden, have access to equipment) to adequately monitor:
the microbiological status of the environment in production areas
the microbiological burden of the veterinary chemical products that are to be sterilised.

Premises
Check
Point No.

Checkpoint

Acceptable

A1-001

Sterile products are manufactured in areas that are designed and managed to minimise microbial and particulate
contamination.

A1-002

Wherever practicable, enclosed systems are employed for product preparation and filling.

A1-003

Sinks and floor drains are excluded wherever possible. Where this is unavoidable, air breaks are fitted between
the machine and sink or drain.

A1-004

Changing rooms are designed as airlocks and provide physical separation of the different stages of changing to
minimise microbial and particulate contamination of operators and protective clothing.

A1-005

Separate airlocks may be appropriate for moving some materials into controlled areas.

A1-006

An interlocking system or a visual and/or audible warning system is fitted to airlocks to prevent the opening of
more than one airlock door at a time.

A1-007

Under all operational conditions, a filtered air supply to a particular area maintains both a positive pressure and a
positive airflow relative to surrounding areas of a lower grade and flushes the area effectively.

KP80_F33

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Premises (cont)
Check
Point No.

A1-008

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

A warning system is provided to indicate failure in the air supply. Indicators of pressure differences are fitted
between areas where these differences are important. These pressure differences are recorded regularly or
otherwise documented.

Production areas
A1-009

Access to buildings is restricted to authorised persons. Visitors are discouraged, kept to a minimum, and generally
permitted only in areas not used for aseptic operations. Visitors clothing is in accordance with the area visited.
All production areas are, as far as possible, designed to avoid the entry of non-operational personnel.

A1-010

All exposed surfaces are smooth, impervious and unbroken in order to minimise the shedding or accumulation of
particles or micro-organisms and to permit the repeated application of cleaning agents and disinfectants. Timber is
not used.

A1-011

To reduce accumulation of dust and to facilitate cleaning, there are no uncleanable recesses and a minimum of
projecting ledges, shelves, cupboards and equipment. Doors are designed to avoid uncleanable recesses.

A1-012

Pipes, ducts and other utilities are installed so that they do not create recesses, unsealed openings and surfaces that
are difficult to clean.

A1-013

False ceilings are sealed to prevent contamination from the space above them.

A1-014

Areas for the manufacture of terminally sterilised product are designed to prevent the mixing of sterilised and nonsterilised products

Sanitation and hygiene

A1-015

Areas used for the production of sterile products are subjected to regular, thorough cleaning and disinfection. The
effectiveness of controlling microbial content of the air and surfaces is routinely monitored.

A1-016

Items brought into sterile manufacturing areas, including means of transport, are of a standard of cleanliness
compatible with the environmental standard for the area.

A1-017

There are specific written procedures for the:

(a) cleaning of bulk containers and their subsequent inspection for release for use in processing;
(b) control of external contamination of bulk containers during use;
(c) assembly of filters and the connecting of hoses and pipelines;

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KP80_F33

Sanitation and hygiene (cont)

Check
Point No.

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

(d) dismantling, cleaning and decontamination of pumps, filters, pipelines, and filling heads and for their
subsequent inspection for release for use in processing.
A1-018

Fumigation (with humidified formaldehyde vapour or other validated method) may be used to reduce microbial
contamination in places inaccessible to surface disinfection. Fogging (such as with peracetic acid) may also be
acceptable if the process is validated.

A1-019

Disinfectants and detergents are monitored for microbial contamination unless pre-sterilised. Diluted disinfectants
and detergents are kept in previously cleaned containers and are only stored for defined periods unless they are
also sterilised.

Environmental control air quality

A1-020

KP80_F33

For the manufacture of sterile medicinal products, four grades of air quality are distinguished, as follows
Grade A:

The local zone for high risk operations, eg filling zone, stopper bowls, open ampoules and vials, aseptic connections. Normally such conditions are
provided by a unidirectional airflow workstation. Unidirectional airflow systems should provide a homogeneous air velocity in the range of 0.360.54
m/s (guidance value) at the working position in open cleanroom applications. The maintenance of unidirectional airflow are demonstrated. A
unidirectional airflow at lower velocities may be used in closed isolators and glove boxes.

Grade B:

This is the background environment for Grade A zone and is used for aseptic preparation and filling,

Grade C/D:

Clean areas for carrying out less critical stages in the manufacture of sterile products.

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A1-021

KP80_F33

The classification of airborne particulate levels for Grades A-D is given in the following table.
Maximum permitted number of particles/m3 of given size(a)
At rest (b)

Grade
A
B
C
D
Notes: (a)

0.5 m (c)
3500
3500
350000
3500000

In operation (b)
5 m
1 (d)
1 (d)
2000
20000

0.5 m (c)
3500
350000
3500000
See Note (e)

5 m
1 (d)
2000
20000
See Note (e)

A discrete airborne particle counter is used to measure the concentration of particles of sizes equal to or greater than the
designated threshold. Where consideration of particulate contamination is necessary to ensure product quality, a
continuous measurement system are used for monitoring the concentration of particles in the Grade A zone, and is
recommended for the surrounding Grade B areas. For routine testing, the total sample volume are not less than 1/m for
Grade A and B areas and preferably also in Grade C areas.
In order to reach the B, C and D air quality grades, the number of air changes are related to the size of the room and the
equipment and personnel present in the room. The air system are provided with appropriate terminal filters such as high
efficiency particulate air (HEPA) filters for grades A, B and C.

A1-022

KP80_F33

(b)

The particulate conditions given in the table for the at rest state are achieved after a short clean up period of 15-20
minutes (guidance value) in an unmanned state after completion of operations. The particulate conditions for grade A in
operation given in the table are maintained in the zone immediately surrounding the product whenever the product or
open container is exposed to the environment. It is accepted that it may not always be possible to demonstrate
conformity with particulate standards at the point of fill when filling is in progress, due to the generation of particles or
droplets from the product itself.

(c)

The guidance given for the maximum permitted number of particles in the at rest and in operation conditions
correspond approximately to the cleanliness classes in the AS/NZS ISO 14644-1 at a particle size of 0.5 m.

(d)

These areas are expected to be completely free from particles of size greater than 5 m. As it is impossible to
demonstrate the absence of particles with any statistical significance, the limits are set to 1 particle/m 3. During the
cleanroom qualification it are shown that the areas can be maintained within the defined limits.

(e)

The requirements and limits will depend on the nature of the operations carried out.

Other characteristics such as temperature and relative humidity depend on the product and the nature of the operations carried out, as well as on personnel comfort.
These parameters should not interfere with the defined cleanliness standard.

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A1-023

KP80_F33

Examples of operations to be carried out in the various air quality grades

Grade
A
C
D

Operations for terminally sterilised products

Filling of products when unusually at risk
Preparation of solutions when unusually at risk and filling of products
Preparation of solutions and components for subsequent filling

Grade
A
C
D

Operations for aseptic preparations

Aseptic preparation and filling
Preparation of solutions to be filtered
Handling of components after washing

Air quality (cont)

Check
Point No.

Checkpoint

Acceptable

A1-024

Operations preceding terminal sterilisation are normally carried out in at least a Grade D environment. Where
there are increased risks of microbial contamination to the product (eg filling of wide-necked containers, or where
the product actively supports microbial growth or must be held before sterilisation), preparation of solutions and
components is carried out in at least a Grade C environment.

A1-025

A floor plan of the manufacturing areas is available, showing the points of entry and exit of air, classification of
each room, number of air changes per hour and the differential pressure(s).

A1-026

Where an isolator is used, the air classification required for the background environment depends on the design of
the isolator and its application. It is controlled and for aseptic processing is at least Grade D.

A1-027

Isolators are introduced only after appropriate validation. Validation takes into account all critical factors of
isolator technology, for example the quality of the air inside and outside (background) the isolator, sanitation of
the isolator, the transfer process and isolator integrity.

A1-028

Monitoring of isolators is carried out routinely and includes frequent leak testing of the isolator and glove/sleeve
system.

A1-029

Blow/fill/seal equipment used for aseptic production that is fitted with an effective Grade A air shower may be
installed in at least a Grade C environment, provided that Grade A/B clothing (see clause A1-041) is used. The
environment should comply with the viable and non-viable limits at rest and the viable limit only when in
operation. Blow/fill/seal equipment used for the production of products for terminal sterilisation is installed in at
least a Grade D environment.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Environmental monitoring
Check
Point No.

Checkpoint

Acceptable

A1-030

Cleanrooms and related areas are monitored at planned intervals for airborne and surface microbiological
contamination and the results obtained used to determine alert and action levels. Monitoring is frequent and
takes place while normal production operations are in progress. In the case of aseptic filling, it provides the basis
for the assessment of aseptic hygiene throughout the filling process. Results are tabulated or graphed and assessed
and if necessary, prompt remedial action taken according to the standards established. Additional testing is carried
out to determine the effectiveness of such operations as cleaning and fumigation and the influence of disruptions
such as spillage or maintenance.

A1-031

Environmental monitoring of clean areas includes the following components:

Minor
non
conformance

Major
non
conformance

Not
Audited

(a) particulate monitoring during routine operation, where relevant;

(b) airborne microbiological monitoring;
-

air samplers sample an adequate quantity of air to provide a meaningful result (see note a, clause A1021);

air monitoring, using both volumetric and settle plate-sampling methods in aseptic fill and seal areas;

(c) microbiological monitoring of surfaces (eg walls, equipment surfaces, bench tops, trolleys and floors);
(d) microbiological monitoring of personnel (eg external surfaces on gloves, sleeves, and torso);
(e) temperature and humidity monitoring; the recommended settings are 18C and 35-50% humidity (too high a
value on either setting will promote particulate and microbial shedding from personnel, and too low a setting
will increase static electricity).
A1-032

The methods used for environmental monitoring are justified.

A1-033

Microbiological and particulate contamination are controlled and monitored for each grade by a comprehensive
procedure approved by quality management staff.

A1-034

Media used for environmental monitoring are able to recover yeasts, moulds, fungi and aerobic bacteria.
Monitoring should include anaerobes where the type of product deems this necessary. It is recommended that two
types of culture media (usually agars) be used for the recovery of the above-mentioned organisms.

A1-035

Isolates found during environmental monitoring are regularly identified.

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KP80_F33

Personnel
Check
Point No.

Checkpoint

Acceptable

A1-036

Management delegate the supervision of the production process for sterile products only to persons who are
qualified by training and/or experience in the relevant aspects of pharmaceutical/microbiological sciences. Where
the person responsible for Quality is not a qualified microbiologist, arrangements are made to obtain regular
external expert microbiological advice.

A1-037

All personnel (including those concerned with cleaning and maintenance) receive training in procedures and in
disciplines relevant to the correct manufacture of sterile products, including hygiene (referred to in Chapter 2,
clauses 223-230) and the basic elements of microbiology using expert microbiological advice. When external
personnel who have not received such training (eg building or maintenance contractors) need to be brought in,
particular care is taken over their supervision.

A1-038

Personnel required to work in clean and aseptic areas are selected with care to ensure that they are not subject to
any chronic disease or condition that would present an abnormal microbiological hazard to the product. The same
principle is applied to visitors to clean rooms.

A1-039

Staff who have been engaged in animal handling, processing of animal tissues or products/materials or culturing
of microorganisms other than those used in the current manufacturing process do not enter sterile-product areas
unless rigorous and clearly defined entry procedures have been followed. These entry procedures may include a
period of quarantine exclusion from the manufacturing area.

A1-040

People entering clean areas follow written entry procedures, including changing and hand washing, which are
designed to minimise contamination of clean area clothing or carry-through of contaminants to clean areas.

A1-041

The minimum protective clothing requirements for each grade of controlled area are as follows:

KP80_F33

Minor
non
conformance

Major
non
conformance

Not
Audited

Grade A/B:

Headgear should totally enclose hair and, where relevant, beard and moustache; it are tucked into the neck of the suit. A facemask are worn to prevent the
shedding of droplets. Sterilised, non-powdered rubber or plastic gloves and sterilised or disinfected footwear are worn. Trouser-bottoms are tucked inside
the footwear and garment sleeves into the gloves. The protective clothing should shed virtually no fibres or particulate matter and retain particles shed by
the body.

Grade C:

Hair and, where relevant, beard and moustache are covered. Non-powdered gloves are worn. A single or two-piece trouser suit, gathered at the wrists and
with high neck and overshoes or dedicated shoes are worn. They should shed virtually no fibres or particulate matter.

Grade D:

Hair and, where relevant, beard and moustache are covered. A suitable protective garment and overshoes or dedicated shoes are worn. Gloves (nonpowdered) may be required

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KP80_F33

Equipment
Check
Point No.

Checkpoint

Acceptable

A1-042

Unidirectional airflow equipment is regularly tested and the results recorded.

A1-043

Where necessary, equipment is sterilised before use. The effect of the sterilisation methods on the operation and
durability of equipment is considered. All sterilisation procedures are validated.

A1-044

Equipment used in the processing of sterile products before sterilisation is designed and operated to minimise
contamination by microorganisms and particulate matter. As far as practicable, equipment, fittings and services
are designed and installed so that maintenance and repairs may be carried out without personnel having to enter
the cleanroom. If sterilisation is required, it is carried out after complete reassembly wherever possible.
Maintenance tools and equipment are cleaned, disinfected or sterilised before use.

A1-045

Vessels containing bulk sterile-filtered water or product are vented through bacteria-retaining filters.

A1-046

Autoclaves, gas sterilisers, sterilising ovens, and lyophilisers are equipped with automatic recorders that monitor
the time and temperature and, where necessary, other parameters of the sterilising cycle. This equipment is
qualified upon installation and is calibrated periodically. Records confirm that these parameters have been
achieved with an appropriate degree of accuracy.

A1-047

A temperature-sensing probe for the automatic temperature recorder is located at the position in the steriliser
shown by previous studies to be the coolest part of the loaded chamber. Where sterilisers are fitted with a drain at
the bottom of the chamber, it may also be necessary to record the temperature at this position throughout the
sterilisation period. There are regular leak tests on the chamber when a vacuum phase is part of the cycle.

A1-048

Heat sterilisers have provision for the entry of leads from temperature sensing devices placed in product packs or
simulated product packs during heat penetration studies.

A1-049

The pressure during steam sterilising cycles is recorded at least manually.

A1-050

Steam used for sterilisation does not contain additives at a level that could cause contamination of product or
equipment. The use of clean steam may need to be considered.

A1-051

Where the quality of the product may be affected, air or any other gas admitted to an autoclave, hot air steriliser or
lyophiliser or used to promote positive pressure for filtration, is filtered through a bacteria-retaining filter.
Compressed air used is also filtered through a bacteria-retaining filter.

A1-052

Water treatment plants and distribution systems are designed, constructed and maintained so as to ensure a reliable
source of water of an appropriate quality. They are not operated beyond their designed capacity. Water is
produced, stored and distributed in a manner that prevents microbial growth; for example, by constant circulation
at a temperature above 80C or at 4C or below.

KP80_F33

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Equipment (cont)
Check
Point No.

A1-053

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

All water systems supplying processed water for product manufacture are monitored for:
(a) total organic carbon;
(b) conductivity;
(c) endotoxin;
(d) microbial quality.

Specifications for materials

A1-054

Specifications for raw materials consider microbial limits and any special storage requirements.

A1-055

Water used in the preparation of sterile products complies with the relevant pharmacopoeial standards or
registration requirements. It may not need to be sterilised before the product is manufactured.

A1-056

When distilled water is used in the final product, the time between distillation and the final production does not
exceed 24 hours unless provision is made for it to be held at a temperature of at least 80C. A limit on the time
that may elapse between solution preparation and sterilisation is also set.

Processing
A1-057

Containers or other materials liable to generate particles or fibres are not taken into areas supplied with Grade A,
B or C air.

A1-058

The intervals between the washing, drying and sterilisation of components, containers and equipment is as short as
possible and subject to a time limit appropriate to the storage conditions. The interval between sterilisation and
the use of these materials is also subject to a time limit.

A1-059

The time between the start of the preparation of a solution and its sterilisation is as short as possible and subject to
a limit for each product that takes into account its composition and the prescribed method of storage. Unless
special storage conditions are provided, bulk aqueous solutions have no greater volume than can be used in one
working day and are filled into final containers and sterilised within one working day.

A1-060

The microbiological load of products is as low as practicable before sterilisation. It is monitored and an action
level set that is related to the efficiency of the method of sterilisation to be used, the risk of pyrogens and previous
validation results. All solutions and in particular, large volume infusion fluids are passed through a filter of pore
size 0.45 m, where possible immediately before filling.

KP80_F33

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KP80_F33

Processing (cont)
Check
Point No.

Checkpoint

Acceptable

A1-061

Batch processing records for sterile products include details of the sterilisation of the batch and, where the batch is
aseptically processed, details of the sterilisation of the components and equipment used.

A1-062

The charts of automatic recorders of cycle parameters constitute part of the batch processing records of sterile
products and are marked to identify the batch or batches to which each applies.

A1-063

Sterilisation records are reviewed and approved as part of the batch release procedure.

A1-064

Each separate sterilising basket, package, pallet, etc, of products or components undergoing sterilisation is
fastened, wired, sealed, lidded or otherwise secured to prevent mix-up. It bears, in a conspicuous position, a
visual indicator to demonstrate whether it has passed through a sterilisation cycle.

A1-065

Microbiological indicators are quarantined and subjected to quality control before use.

A1-066

Preparations of microbiological origin are not be made or filled in areas used for the processing of other medicinal
products, unless justified by a written risk analysis.

A1-067

Components, containers and equipment are handled after the final cleaning process in such a way that they are not
re-contaminated.

A1-068

Each procedure used for the sterilisation of a particular quantity or volume of a material component or product has
been shown by validation studies to be effective and reliable. The validation is verified at scheduled intervals
based on performance history, or when any significant change is made in the process or equipment.

A1-069

Where practicable, heat sterilisation is the method of choice. In any case, the sterilisation process is in accordance
with product registration.

A1-070

Validated loading patterns are established for all sterilisation processes.

A1-071

Biological indicators are considered as an additional method for monitoring the sterilisation process. They are
stored and used according to the manufacturers instructions, and their quality checked by positive controls. If
biological indicators are used, strict precautions are taken to avoid transferring microbial contamination from them

Minor
non
conformance

Major
non
conformance

Not
Audited

Sterilisation by heat general issues

A1-072

Each heat sterilisation cycle is recorded on a time/temperature chart with a suitably large scale or by other
appropriate equipment with suitable accuracy and precision.

A1-073

Chemical or biological indicators may also be used, but must not take the place of physical measurements.

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KP80_F33

Sterilisation by heat general issues (cont)

Check
Point No.

Checkpoint

Acceptable

A1-074

Sufficient time is allowed for the whole of the load to reach the required temperature before measurement of the
sterilising time is commenced. This time is determined for each type of load. Typical loading diagrams are part of
the standard operating procedures. Each sterilising load contains one or more indicators to show that the cycle has
been completed.

A1-075

After the high-temperature phase of a heat sterilisation cycle, precautions are taken to prevent contamination of a
sterilised load during cooling. Any cooling fluid or gas in contact with the product is sterilised, unless it can be
shown that any leaking container would not be approved for use.

Minor
non
conformance

Major
non
conformance

Not
Audited

Sterilisation by moist heat

A1-076

Both temperature and pressure are used to monitor the process. Control instrumentation is independent of
monitoring instrumentation and recording charts. Where automated control and monitoring systems are used for
these applications, they are validated to ensure that critical process requirements are met. System and cycle faults
are registered by the system and evident to the operator. The reading of the independent temperature indicator is
routinely checked against the chart recorder during the sterilisation period.

A1-077

The items to be sterilised are wrapped in a material that allows removal of air and penetration of steam but
prevents recontamination after sterilisation. All parts of the load are in contact with the sterilising agent at the
required temperature for the required time.

Sterilisation by dry heat

A1-078

Equipment for dry heat sterilisation allows air circulation within the chamber and the maintenance of a positive
pressure to prevent the entry of non-sterile air. Any air admitted is passed through a HEPA filter. Where this
process is also intended to remove pyrogens, challenge tests using endotoxins are used as part of the validation.

Sterilisation by radiation
A1-079

The radiation dose is measured during the sterilisation procedure. For this purpose, dosimetry indicators that are
independent of dose rate are used, giving a quantitative measurement of the dose received by the product itself.
These dosimeters are inserted in the load in sufficient number, close enough together to ensure that there is always
a dosimeter in the irradiator. The position in the carrier receiving the lowest dose and where appropriate, the
highest dose are represented. Where plastic dosimeters are used, they are used within the time limit of their
calibration. Dosimeter absorbances are read soon after exposure to radiation.

A1-080

Biological indicators may be used as an additional control.

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KP80_F33

Sterilisation by radiation (cont)

Check
Point No.

Checkpoint

Acceptable

A1-081

Validation procedures ensure that the effects of variations in density of the packages are considered.

A1-082

Materials handling procedures prevent mix-up between irradiated and non-irradiated materials. Radiationsensitive colour indicators are also used on each package to differentiate between packages that have been
subjected to irradiation and those that have not.

A1-083

The total radiation dose is administered within a pre-determined time span.

A1-084

If an outside contractor carries out sterilisation by radiation, the contract giver is responsible for ensuring that the
requirements for this type of sterilisation are met and that the process is validated. The responsibilities of the
radiation plant operator (eg for using the correct dose) are also be specified.

A1-085

Ultraviolet irradiation is not normally an acceptable method of sterilisation.

Minor
non
conformance

Major
non
conformance

Not
Audited

Sterilisation by ethylene dioxide

A1-086

This method is only used when no other method is practicable. During process validation, it is shown that there is
no damaging effect on the product and that the conditions and time allowed for degassing are such as to reduce
any residual gas and reaction products to defined acceptable limits for the type of product or material.

A1-087

Before exposure to the gas, materials are brought into equilibrium with the humidity and temperature required for
the process. The time required for this is balanced against the opposing need to minimise the time before
sterilisation.

A1-088

Each sterilisation cycle is monitored with suitable biological indicators, using the appropriate number of test
pieces distributed throughout the load. The information so obtained forms part of the batch record.

A1-089

For each sterilisation cycle, records are made of the time taken to complete the cycle, the pressure, temperature
and humidity within the chamber during the process and the gas concentration and the total amount of gas used.
The pressure and temperature are recorded throughout the cycle on a chart. These records should form part of the
batch record.

KP80_F33

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KP80_F33

Sterilisation by filtration
Check
Point No.

Checkpoint

Acceptable

A1-090

Solutions or liquids are filtered through a sterile filter of nominal pore size of 0.22 m, or with at least equivalent
micro-organism retaining properties, into a previously sterilised container. Consideration is given to
complementing the filtration process with heat or other treatment where the presence of filterable microorganisms
is suspected.

A1-091

Positive pressure rather than negative pressure is used in filtration processes. To enhance the assurance of sterility,
a second filtration step immediately before filling, may be advisable.

A1-092

Fibre-shedding characteristics of filters are minimal. Asbestos-containing filters are not used under any
circumstances.

A1-093

The same filter is not used for more than one working day, unless such use has been validated.

A1-094

The filter does not affect the product by removal of ingredients from it or by release of substances into it.

A1-095

The integrity of the sterilised filter is verified immediately after use by an appropriate method, such as a bubble
point, diffusive flow or pressure hold test. Integrity testing before and during use should also be considered. The
time taken to filter a known volume of bulk solution and the pressure difference to be used across the filter, are
determined during validation and any significant variation from this during routine manufacturing is noted and
investigated. Results of these checks are included in the batch record. The integrity of critical gas and air vent
filters is confirmed after use. The integrity of other filters is confirmed at appropriate intervals.

Minor
non
conformance

Major
non
conformance

Not
Audited

Finishing (Primary packaging)

A1-096

Containers are closed by appropriately validated methods. Containers closed by fusion (eg glass or plastic
ampoules) are subject to 100% integrity testing. Samples of other containers are checked for integrity according
to appropriate procedures.

A1-097

Containers sealed under vacuum are tested for maintenance of that vacuum after an appropriate, pre-determined
period.

A1-098

Filled containers of parenteral products are inspected individually for extraneous contamination or other defects.
When inspection is visual, it is done under suitable and controlled conditions of illumination and background.
Operators doing the inspection are subjected to and pass regular eyesight checks, with spectacles if worn, and are
allowed frequent breaks from inspection. Where other methods of inspection are used, the process is validated
and the performance of the equipment checked at intervals. Results are recorded.

KP80_F33

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KP80_F33

Quality control
Check
Point No.

A1-099

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Where required or appropriate, tests for the following are carried out on each batch of product. For injectable and
large volume infusion solution products, such testing is essential:
(a) sterility;
(b) uniformity of contents;
(c) potency;
(d) pyrogenicity or endotoxin;
(e) particulate matter.

A1-100

Cumulative records of environmental control, the testing of manufacturing equipment, media fill runs and all other
applicable quality control tests are maintained by Quality Control.

A1-101

Pharmacopoeial methods are used for sterility tests. These methods are validated for the product(s) concerned.

A1-102

Where parametric release has been authorised, all calibrations and controls that were specified in the application
for authorisation are rigorously maintained.

A1-103

Samples taken for sterility testing are representative of the whole of the batch, and include samples taken from
parts of the batch considered to be most at risk of contamination, for example:
(a) for products that have been filled aseptically, samples include containers filled at the beginning and end of
the batch and after any significant intervention;
(b)

A1-104

for products that have been heat sterilised in their final containers, samples are taken from the potentially
coolest part of the load.

Release of sterile product includes a review of:

(a) validation studies, including, in the case of aseptic filling, media fill results;
(b) environmental monitoring results;
(c) batch records including in-process test results;
(d) equipment monitoring and performance records;
(e) finished product test records.

KP80_F33

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KP80_F33

Aseptic processing
Premises
Check
Point No.

Checkpoint

Acceptable

A1-105

Aseptic filling involves the minimum of human intervention.

A1-106

Sinks and drains are excluded from aseptic filling/sealing rooms.

A1-107

Airlocks are flushed effectively with filtered air. The final stage of the changing room is, in the at rest state, the
same grade as the area into which it leads. Separate changing rooms for entering and leaving clean areas are
provided where desirable. Hand-washing facilities are provided only in the first (outer) stage of the changing
rooms.

A1-108

Adjacent rooms of different grades have a pressure differential of 10-15 pascals (guidance values). The air-flow
pattern, location of equipment and movement of personnel affords protection of the zone of greatest risk (ie the
immediate environment to which a product and sterilised components that contact the product are exposed).

Minor
non
conformance

Major
non
conformance

Not
Audited

Production areas
A1-109

Products are manufactured in a clean area up to the stage where they are sterilised, and thereafter processed and
filled into their final containers under aseptic conditions, employing a double barrier system. The first barrier is
provided by unidirectional flow workstations in which the actual filling operations are carried out. The second
barrier is provided by the supply of filtered air into the room in which the operations are carried out. It is
desirable to maintain this room at a positive pressure relative to the outside environment.

A1-110

Non-sterile products are not processed in the same area as sterile products.

A1-111

Grade B areas (see clause A1-020) are designed so that all operations can be observed from the outside.

Sanitation and hygiene

A1-112

During aseptic operations, the areas are not used for any other purpose. After any non-sterile operation such as
maintenance, and before aseptic operations are commenced, the areas are thoroughly cleaned and disinfected.

A1-113

Clean and, where necessary, sterile protective clothing is supplied and worn in production areas. Personnel
working in associated areas not designated as clean or aseptic areas change into clean over-garments before
entering the clean or aseptic areas and remove these over-garments on exit. These outer garments are not worn
outside the clean-room suite.

A1-114

Clean over-garments are made of such material and weave that they are comfortable to wear, do not shed fibres,
and restrict the passage of particulate matter. These garments are not fitted with pockets or cuffs.

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KP80_F33

Sanitation and hygiene (cont)

Check
Point No.

A1-115

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Disinfectants and detergents used in Grade A and B areas are sterile before use.

Environmental control
A1-116

The in operation and at rest states are defined for each clean room or suite of clean rooms.

A1-117

Examples of operations to be carried out in the various clean zone grades

Grade
A

Operations for aseptic preparations

Preparation of solutions that are not to be filtered.
Handling of sterile starting materials and components that are not to be filtered.
Handling and filling of aseptically prepared products.
Transfer of partially closed containers, as used in freeze drying.
Preparation and filling of sterile ointments, creams, suspensions and emulsions.

Transfer of partially closed containers in sealed transfer trays.

Preparation of solutions to be filtered.

Handling of components after washing.

Environmental monitoring
A1-118

Sampling methods used during operation do not interfere with zone protection. Results from monitoring are
considered when reviewing batch documentation for finished product release. Surfaces and personnel are
monitored after critical operations.

A1-119

Additional microbiological monitoring may be appropriate after activities such as major maintenance, interruption
to production and equipment validation.

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A1-120

Recommended limits to be used in microbiological monitoring of clean areas (a) during operation:

Grade

Air sample
cfu/m3

A
B
C
D

<1
10
100
200

Notes:

KP80_F33

Sampling method
Settle plates (diam.
Contact plates
90mm) cfu/4 hours
(diam. 55mm)
(b)
cfu/plate
<1
<1
5
5
50
25
100
50

Glove print
(5 fingers)
cfu/glove
<1
5
-

(a)

These are average values.

(b)

Individual settle plates may be exposed for less than 4 hours, but should not be exposed for more
than 4 hours unless validated. Additional plates may be used at a single location to sum to four
hours exposure. The results from settle plates should not be interpreted as equivalent to those from
volumetric sampling. cfu = colony forming units

Environmental monitoring (cont)

Check
Point No.

A1-121

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

It can be demonstrated that airborne cleanliness classifications are met during operations. Appropriate alert and
action limits are set for the results of particulate monitoring. Operating procedures prescribe corrective action, if
these limits are exceeded.

Personnel
A1-122

Only the minimum number of personnel essential for production and in-process control operations are allowed in
aseptic or clean areas, particularly during aseptic processing. Inspections and controls are conducted outside the
clean areas as far as possible.

A1-123

Personnel engaged in servicing equipment or other non-routine activities observe the same precautions and
hygiene standards as production personnel.

A1-124

Wrist watches, make-up and jewellery are not worn in clean areas.

A1-125

Outdoor clothing is not brought into changing rooms leading to Grade B and C rooms. Clean sterile (sterilised or
adequately sanitised) protective garments are provided at each work session for every worker in a Grade A/B area.
Gloves are regularly disinfected during operations. Masks and gloves are changed at least at every working
session.

KP80_F33

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KP80_F33

Personnel (cont)
Check
Point No.

A1-126

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

Clean area clothing is cleaned and handled in such a way that it does not gather additional contaminants that can
later be shed. These operations follow written procedures. Separate laundry facilities are provided for such
clothing.

Equipment
A1-127

A conveyor belt should not pass through a partition between a Grade A or B area and a processing area of lower
air cleanliness, unless the belt itself is continually sterilised (eg in a sterilising tunnel).

Processing
A1-128

Activities in clean areas, especially when aseptic operations are in progress, are kept to a minimum and movement
of personnel is controlled and methodical to avoid excessive shedding of particles and organisms as a result of
over-vigorous activity. The ambient temperature and humidity are set to provide a comfortable environment,
taking into account the nature of the garments worn.

A1-129

Components, containers, equipment and any other article required in a clean area where aseptic work takes place
are sterilised and passed into the area through double-ended sterilisers sealed into the wall, or by a procedure that
achieves the same objective of not introducing contamination. Non-combustible gases are passed through
microorganism-retentive filters.

A1-130

Validation of aseptic processing includes a process simulation test using a nutrient medium (media fill). The
process simulation test imitates as closely as possible the routine aseptic manufacturing process, including
predictable interventions and worst-case situations. Process simulation tests are performed as an initial validation
with three consecutive satisfactory simulation tests per shift and then repeated at defined intervals (not less than
once annually) and after any significant modification to the heating, ventilation and air conditioning (HVAC)
system, equipment, process or number of shifts. The number of containers used for media fills is sufficient to
enable a valid evaluation. For small batches, the number of containers for media fills is at least equal to the size of
the product batch. The target is zero growth, but production need not be halted if a contamination rate of less than
0.1% is observed. The manufacturer has establish alert and action limits.

A1-131

Care is taken that any validation does not compromise the processes

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KP80_F33

Key observations and comments (Comment on both positive and negative aspects of Sterile Product manufacture. Record evidence sighted and reviewed, such as
SOPs, records, observations, etc, particularly with respect to non-conformance) .

KP80_F33

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ANNEX 2

KP80_F33

Immunobiologicals and other products of biological origin

Manufacturing principles
Veterinary immunological products and other chemical products of biological origin, including those that are manufactured using a specified biological process, must be
manufactured:
using only biological starting materials that are, or are derived from biological materials demonstrated to be as free as practicable from adventitious contamination;
in premises designed, constructed and maintained so as to provide an appropriate level of containment of the biological or microbiological agents being handled and to
permit effective decontamination from these agents or from toxic residues by procedures that
- are established and validated by the manufacturer
- maintain the safety of personnel
in cases where uniformity of product depends on deriving batches from a seed lot
- by maintaining the lots in secure and protective storage
- by keeping meticulous records of their origin and disposition.

Premises-general
Check
Point No.

Checkpoint

Acceptable

A2-001

Documentation relating to the premises is readily available, including a detailed description (with plans and
explanatory notes) of the manufacturing site and buildings, showing the designation and conditions of use of all
rooms as well as the biological agents that are handled in them. The flow of people and product is clearly marked.

A2-002

Animal species accommodated in animal houses or otherwise on the site are identified on the site plans or
accompanying notes.

A2-003

Activities carried out in the vicinity of the site are also indicated on the site plans or accompanying notes. Plans of
clean or contained areas describe the ventilation system, indicating inlets and outlets, filters and their
specifications, the number of air changes per hour and pressure differentials. They indicate which pressure
differentials are monitored by pressure indicators.

Minor
non
conformance

Major
non
conformance

Not
Audited

Premises - Segregation and containment

A2-004

KP80_F33

Premises are designed in such a way as to control both the risk to the product and to the environment. This can be
achieved by the use of clean contained and/or controlled areas.

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KP80_F33

Premises - Segregation and containment (cont)

Check
Point No.

Checkpoint

Acceptable

A2-005

Live biological agents are handled in contained areas that may also be clean areas. The level of containment
should depend on the pathogenicity of the microorganism and whether it has been classified as exotic.

A2-006

Inactivated biological agents are handled in clean areas. Clean areas are also used when handling non-infected
cells isolated from multi-cellular organisms and filtration-sterilised media.

A2-007

Open circuit operations involving non-viable products or components not subsequently sterilised are carried out
within a unidirectional Grade A airflow workstation in a Grade B area.

A2-008

Other operations where live biological agents are handled, such as quality control, research and diagnostic
services, are contained and separated if production operations are carried out in the same building. The movement
of personnel and the level of containment should depend on the pathogenicity and origin of the biological agents.
Where there is the risk of introducing highly pathogenic or exotic organisms (eg via quality control activities), the
level of containment is adequate to cope with all such risks. Containment may also be required if quality control
or other activities are carried out in buildings in close proximity to those used for production.

A2-009

Contained areas have the characteristics detailed below.

Minor
non
conformance

Major
non
conformance

Not
Audited

(a) They are capable of easy disinfection.

(b) They have no direct venting to the outside.
(c) Ventilation systems have pressure differentials to contain organisms from the environment and protect the
product from external contamination. Air is extracted through filters appropriate to the organisms being
handled and not recirculated except to the same area. However, the recycling of air between areas may be
permissible, provided it is appropriately filtered.
(d) They have a system for the collection and disinfection of liquid effluents, including contaminated condensate
from sterilisers, bioreactors etc. Solid wastes, including animal carcasses, are disinfected, sterilised or
incinerated as appropriate. Contaminated filters are removed using a safe method.
(e) They have changing rooms designed and used as air locks, and equipped with washing and showering
facilities as appropriate. Air pressure differentials are such that there is no flow of air between the work area
and the external environment or risk of contamination of outer clothing worn outside the area.
(f)

KP80_F33

An air lock system for the passage of equipment, is constructed so that there is no flow of contaminated air
between the work area and the external environment, or risk of contamination of equipment within the lock.
The air lock is of a size that enables the effective surface decontamination of materials being passed through
it. It is preferable that a timing device is installed on the door interlock to allow sufficient time for the
decontamination process to be effective.

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Premises - Segregation and containment (cont)

Check
Point No.

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

(g) There is a barrier double-door autoclave for the secure removal of waste materials and introduction of sterile
items, where appropriate.
(h) Transfer hatches and changing rooms have an interlock mechanism or other appropriate system to prevent the
opening of more than one door at a time. Changing rooms are supplied with air filtered to the same standard
as that for the work area, and are exhausted to produce an adequate air circulation independent of that of the
work area. Transfer hatches are normally ventilated in the same way, but unventilated hatches, or those
equipped with supply air only, may be acceptable.
A2-011

With the exception of blending and subsequent filling operations, only one biological agent at a time is handled
within an area. Production operations such as cell maintenance, media preparation, or virus culture likely to cause
contamination are not performed in the same area at the same time. Where the same room is used for more than
one purpose, effective decontamination and line clearance between operations are in place.

A2-012

Production areas where biological agents particularly resistant to disinfection (eg spore-forming bacteria) are
handled are separated and dedicated to that particular purpose until the biological agents have been inactivated.

A2-013

Killed vaccines are blended, filled, and sealed under aseptic conditions and segregated from the processing areas
where culturing is carried out.

A2-014

The filling of containers with live vaccines, including those prepared from attenuated strains, is appropriately
separated from other aseptic filling operations. This may be achieved by using separate areas or by elapsed time
and effective decontamination procedures.

Premises -Sanitation, disinfection and waste disposal

A2-015

Sanitation, disinfection, decontamination and disposal of wastes and effluents are particularly important in the
manufacture of immunobiological and other biological products. Procedures and equipment protect the product
and avoid environmental contamination. Autoclaving and incineration are the preferred methods of
decontamination of rubbish and waste material, although chemical inactivation may be acceptable in some
circumstances.

A2-016

Production areas are thoroughly cleaned and disinfected after any non-sterile operation, such as maintenance and
before aseptic processing resumes.

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KP80_F33

Personnel
Check
Point No.

Checkpoint

Acceptable

A2-017

In the case of biological agents known to cause disease in humans, adequate measures are taken to prevent
infection of personnel working with live organisms or with animals. Where relevant, personnel are appropriately
vaccinated and subject to regular medical examination.

A2-018

Adequate measures are taken to prevent biological agents being carried outside the manufacturing plant by
personnel. Dependent on the type of biological agent, such measures may include complete changing of clothes
and compulsory showering before leaving the production area.

A2-019

Prevention of product contamination by personnel is achieved by a set of measures and procedures that ensure that
appropriate protective clothing is used during the different stages of the production process. Personnel do not pass
from one area to another unless they have taken appropriate measures to eliminate the risk of contamination.

A2-020

Only personnel essential for production and in-process control operations, maintenance and cleaning are allowed
into processing areas.

A2-021

Personnel working in areas designated as clean/aseptic or culturing change into clean over-garments before
moving from one area to another, and the over-garments are removed on exit from the relevant area. The same
principles apply when staff move from other areas into clean/aseptic or culturing areas.

Minor
non
conformance

Major
non
conformance

Not
Audited

Equipment
A2-022

Any closed equipment used for the primary containment of biological agents is designed and constructed to
prevent any leakage or the formation of droplets and aerosols. Inlets and outlets for gases are protected to achieve
adequate containment (eg by the use of sterilising hydrophobic filters). The introduction or removal of material
takes place using a sterilisable closed system, or possibly in an appropriate unidirectional air flow.

A2-023

Separate incubators are used for infected and non-infected containers and also generally for different organisms or
cells. Incubators containing more that one organism or cell type will only be acceptable if adequate measures are
in place to seal, surface decontaminate and segregate the containers. All containers are individually labelled.
Equipment used for the storage of biological agents or products is designed and used in such a manner as to
prevent any possible mix-up. All stored items are clearly and unambiguously labelled and kept in leak-proof
containers. Items such as seed stock (cell or organism) are stored in dedicated equipment.

A2-024

For single-ended freeze-driers, the clean room is decontaminated at the end of the process and before a further
manufacturing batch is introduced into the area, unless this contains the same organisms. Double-door freezedriers are sterilised after each cycle unless opened in a clean area. Sterilisation of freeze-driers is done at least
after each campaign.

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KP80_F33

Equipment (cont)
Check
Point No.

Checkpoint

Acceptable

A2-025

Equipment used in the culturing of microorganisms is capable of decontamination, either in situ or otherwise, and
is capable of effective cleaning before re-use and/or sterilisation.

A2-026

In heat sterilising processes, steps are taken to ensure that the whole load reaches the sterilisation temperature.
Account is taken of heat-up times for various loads and typical loading diagrams are part of standard operating
procedures. Standard operating procedures are available.

A2-027

Items to be sterilised by autoclaving are wrapped in a material that allows the removal of air (either by free steam
or evacuation of the chamber) and its replacement by steam, but does not permit recontamination when dry.

A2-028

Sterilisation by filtration should not be used when sterilisation by heat is acceptable. Positive pressure rather than
negative pressure is used in filtration processes. The integrity of the filter system is tested immediately after each
use.

A2-029

When re-useable filters are used, they are effectively cleaned and sterilised after each use. Consideration is given
to using individual filters for one type of solution only.

A2-030

Unidirectional airflow equipment is regularly tested and the results recorded. Cleanrooms and related areas are
monitored at planned intervals for microbiological contamination.

Minor
non
conformance

Major
non
conformance

Not
Audited

Animals and animal houses

A2-031

The sanitary status of the animals used for production is defined, monitored, and recorded. Animals are handled
in ways defined in specific monographs (e.g. specific pathogen free [SPF] flocks), where these are available and
relevant.

A2-032

Animals, biological agents and tests carried out are identified in such a way as to prevent any risk of confusion
and to control all foreseeable hazards.

A2-033

Animal testing facilities are sufficiently secure to ensure that unauthorised entry is prevented and that animals
cannot break in or escape. This applies particularly to facilities where live challenge tests are being carried out.
Procedures are in place to ensure that animals cannot be incorrectly identified or otherwise mixed up by staff.
Attention is also given to decontamination and environmental requirements, where applicable.

A2-034

Animal houses accommodating animals used for, or intended to be used for, production purposes are provided
with appropriate containment and/or clean area measures and are separated from other animal accommodation.

A2-035

Animal houses accommodating animals that are used for quality control purposes that involve pathogenic
biological agents are adequately contained.

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Production - general
Check
Point No.

Checkpoint

Acceptable

A2-036

Production of biological agents may take place in either clean or controlled areas, provided it is carried out in
totally enclosed and heat sterilised equipment, with all connections being also heat sterilised after making and
before breaking. It may be acceptable for connections to be made under local unidirectional airflow, provided
these are few in number and proper aseptic techniques are used and there is no risk of leakage. The sterilisation
parameters used before breaking the connections are validated for the organisms being used. Different products
may be placed in different bioreactors within the same area, provided that there is no risk of accidental crosscontamination. However, organisms generally subject to special requirements for containment are in areas
dedicated to such products.

A2-037

Critical procedures, including methods for sterilisation, disinfection, virus removal and inactivation, are validated
and subject to monitoring and in-process controls.

A2-038

Substances of animal origin are prepared from homogeneous bulk material, designated with a batch number. A
batch may contain material derived from as many animals as is desired, but once designated and given a batch
number, a batch is not added to or contaminated in any way.

Minor
non
conformance

Major
non
conformance

Not
Audited

Production - starting materials

A2-039

Written specifications for starting materials, where appropriate, include details of the supplier, the method of
manufacture, the geographical origin and the animal species from which the materials are derived. The controls to
be applied to starting materials are included. Microbiological controls are particularly important.

A2-040

The results of tests on starting materials comply with the specifications. Where the tests take a long time, it may
be necessary to process starting materials before the results of analytical controls are available. In such cases, the
release of a finished product is conditional upon satisfactory results of the tests on starting materials.

A2-041

Where substances of animal origin (eg trypsin and serum albumin) are used as ingredients of culture media, during
processing or as added constituents of vaccines or diluents, batch records allow traceability and confirmation with
registered specifications and quarantine requirements for all such substances.

Production - media
A2-042

Media used in fermenters or bioreactors is sterilised in situ or in line, preferably by heat. Gases, media, acids,
alkalis, defoaming agents and other materials introduced into sterile bioreactors are themselves sterile.

A2-043

Where heat-labile media components are required, these are sterilised by other acceptable means (eg filtration,
gamma irradiation) and added aseptically to the heat-sterilised base medium.

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KP80_F33

Production - seed lot and cell bank system

Check
Point No.

Checkpoint

Acceptable

A2-044

In order to prevent unwanted genetic drift, the production of immunobiological products obtained by microbial,
cell or tissue culture, or propagation in embryos and animals, are based on a system of seed lots and/or cell banks.

A2-045

The origin, history since receipt, preparation, form and storage conditions of seed material are described in full.
The number of generations (doublings, passages) between the master seed lot or cell bank and the finished product
is defined and consistent with the product registration. Seed lots and cell banks are adequately characterised and
tested for contaminants. Acceptance criteria for new seed lots and cell banks are established.

A2-046

During the establishment of a seed lot or cell bank, no other living or infectious material is handled at the same
time in the same area or by the same person. Seed lots and cell banks are established, stored and used in such a
way as to minimise the risks of mis-identification, contamination or any alteration.

A2-047

Evidence of the stability and recovery of the seeds and cell banks is generated and recorded. Storage containers
are secure, clearly labelled and held at an appropriate temperature. Storage conditions are properly monitored. An
inventory of each seed lot and cell bank is maintained and each container accounted for.

A2-048

Only authorised personnel are allowed to issue and handle seed material.

Minor
non
conformance

Major
non
conformance

Not
Audited

Production operating techniques

A2-049

The formation of droplets and the production of foam is avoided or minimised during manufacturing processes.
Centrifugation and blending procedures that may lead to droplet formation are carried out in appropriate clean or
contained areas to prevent transfer of live organisms.

A2-050

There are documented procedures for the prompt handling of spillages of live organisms. Validated
decontamination measures are available for each organism. Where different strains of a single species of bacteria
or very similar viruses are involved, the process need be validated against only one of them, unless there is reason
to believe that they may vary significantly in their resistance to the agent(s) involved.

A2-051

Operations involving the transfer of materials such as sterile media, cultures or product are carried out in presterilised closed systems wherever possible. Where this is not possible, transfer operations are protected by
unidirectional airflow workstations. Checks are made to ensure that vessels are correctly connected when addition
of cultures takes place.

A2052

After connection, before the flow of product, and again before disconnection fermenter sampling, addition ports
and connectors are sterilised with steam. However, in some circumstances, chemical disinfection of ports and
unidirectional air flow protection of connections may be acceptable.

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KP80_F33

Production operating techniques (cont)

Check
Point No.

Checkpoint

Acceptable

A2-053

Equipment, glassware, the external surfaces of product containers and other such materials are disinfected using a
validated method before transfer from a clean or contained area. Only the absolute minimum of batch
documentation enters and leaves the area. If obviously contaminated, such as by spills or aerosols, or if the
organism involved is an exotic, the paperwork must be adequately disinfected through an equipment transfer
hatch, or the information transferred out by alternate means.

A2-054

Liquid or solid wastes are sterilised or disinfected before transfer from a clean or contained area. However,
alternative transfer procedures may be appropriate in some cases.

A2-055

Articles and materials, including documentation, entering a production room are carefully controlled to ensure that
only materials concerned with production are introduced.

A2-056

All materials entering a clean or contained area are sterilised. Where practicable, heat-stable articles and materials
entering a clean or contained area do so through a double-ended autoclave or oven. Sterilisation of articles and
materials elsewhere is acceptable, provided they enter through an airlock and appropriate precautions are taken (eg
double wrapping, surface disinfection).

A2-057

Precautions are taken to avoid contamination or confusion during incubation. There is a cleaning and disinfection
procedure for incubators.

A2-058

With the exception of blending and subsequent filling operations, or when totally enclosed systems are used, only
one live biological agent is handled within a production room at any given time. Production rooms are effectively
disinfected between the handling of different live biological agents.

A2-059

Addition of inactivating agent to the bulk material is immediately followed by stirring or mixing to ensure even
distribution of the agent. The bulk material is then transferred to a sterile inactivation vessel to ensure all of the
bulk material is exposed to the inactivating agent.

A2-060

Vessels containing inactivated product are not opened or sampled in areas containing live biological agents. All
subsequent processing of inactivated products takes place in Grade A/B clean areas or enclosed equipment
dedicated to inactivated products.

A2-061

Containers of bulk material are sealed, appropriately labelled and stored under specified conditions.

A2-062

There is a system to assure the integrity of all containers and their closures after filling. This requirement applies
to containers of bulk materials, intermediates and finished products.

A2-063

The capping of vials containing live biological agents is performed in such away that contamination of other
products, or escape of the live agents into other areas or the external environment, does not occur.

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Minor
non
conformance

Major
non
conformance

Not
Audited

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KP80_F33

Production operating techniques (cont)

Check
Point No.

A2-064

Checkpoint

Acceptable

Minor
non
conformance

Major
non
conformance

Not
Audited

When there is a delay between the filling of final containers and their labelling and packaging, procedures are
specified for the storage of unlabelled containers so as to preserve product identity and to ensure satisfactory
storage conditions.

Quality control
A2-065

In-process controls that are crucial to product quality, but which cannot be carried out on the finished product, are
performed at an appropriate stage of production.

A2-066

Where testing of bulk or intermediate materials is required, a sufficient quantity of sample is retained, under
appropriate storage conditions, to allow repetition or confirmation of the test result if necessary.

A2-067

Where production of a biological product involves continuous culture, the quality control requirements arising
from such a production method are appropriately addressed.

A2-068

Sufficient quality control testing is undertaken to ensure that the product complies with the approved registration
particulars.

A2-069

Quality Control maintains cumulative records of environmental control, the testing of manufacturing equipment
and all other quality control tests where applicable, and takes into account the results of such testing before
releasing any batch of product for distribution.

Key observations and comments (Comment on both positive and negative aspects of the manufacture of Immunobiological and other Biological products. Record
evidence sighted and reviewed, such as SOPs, records, observations, etc, particularly with respect to non-conformance) .

KP80_F33

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KP80_F33

NON-STERILE THERAPEUTIC PRODUCTS

(other than ectoparasiticides, premixes, supplements and biological feed additives)
ANNEX 3

Check
Point No.

Checkpoint

Acceptable

A3-001

Production areas where the product or cleaned production equipment are exposed are adequately protected from
the outside environment.

A3-002

The chemical and microbiological quality of water used for production are specified and monitored.

A3-003

Mixing and filling processes ensure homogeneity. Procedures are in place to ensure that homogeneity is
maintained during filling and after stoppages.

A3-004

When the finished product is not packaged immediately after processing, the maximum period of storage and the
storage conditions are specified and respected.

Minor
non
conformance

Major
non
conformance

Not
Audited

Special measures are taken to minimise microbial contamination of liquids, creams, pastes, gels and ointments;
and to ensure that water quality is appropriate
Special measures are taken to minimise cross-contamination and facilitate cleaning in powder and tablet making
facilities.
Where penicillins and other highly sensitising materials are used, special measures are taken to avoid crosscontamination and protect operators.
Where products such as bloat oils and slow release intra-ruminal devices are made in non-pharmaceutical
facilities, steps are taken to ensure that relevant aspects of GMP are complied with.

Key observations and comments (Comment on both positive and negative aspects of Non-Sterile Therapeutic product manufacture. Record evidence sighted and
reviewed, such as SOPs, records, observations, etc, particularly with respect to non-conformance) .

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ANNEX 4
Check
Point No.

HERBAL PRODUCTS

Checkpoint

Acceptable

A4-001

Some plants, extracts, tinctures and other preparations may require special conditions of humidity, temperature or
light protection. These conditions are provided and monitored.

A4-002

Apart from the requirements described in the core elements of this code (see Chapter 5), specifications for
medicinal crude plants include, as far as possible:

A4-003

KP80_F33

the full botanical name (including, if appropriate, the name of the originator of the classification, eg
Linnaeus);

the preferred source of the plant (country or region of origin and, where applicable, method of cultivation,
time of harvesting, collection procedure, pesticides that can/cannot be used, etc);

plant description, including macroscopic and microscopic details, where a whole plant is sourced; an
authentic reference specimen is available for identification purposes;

the part of the plant required (ie whether the whole plant or only a specific part such as the roots, leaves,
whole top, etc);

the method used for drying;

a physical description of the material;

suitable identification tests, including, where appropriate, tests for known active ingredients, or markers,
and the limits accepted ;

acceptable levels of possible chemical or biological contamination (pesticide, fungicide, herbicide, fungal
and/or microbial, including aflatoxins, pest infestations, toxic metals, and other possible contaminants and
adulterants), as well as the methods used to determine such contamination;

tests for foreign materials.

Minor
non
conformance

Major
non
conformance

Not
Audited

Any treatment used to reduce fungal/microbial contamination or other infestation is documented. Specifications
for such procedures are available and include details of processes, tests and limits for residues.

Key observations and comments (Comment on both positive and negative aspects of Herbal product manufacture. Record evidence sighted and reviewed, such as
SOPs, records, observations, etc, particularly with respect to non-conformance) .

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ANNEX 5
Check
Point No.

KP80_F33

ECTOPARASITICIDES

Checkpoint

Acceptable

A5-001

Ectoparasiticides are made in segregated areas or separate buildings, using equipment that is dedicated to this type
of product. Use of common equipment may be accepted, provided that cross-contamination is controlled by
scheduling and use of a validated cleaning procedure.

A5-002

Where ectoparasiticides are manufactured in a facility that also manufactures agricultural chemicals, they are
made in a separate area of the plant, using equipment dedicated to veterinary chemical manufacture. Special
measures are taken to prevent cross-contamination with agricultural chemicals, particularly where shared
facilities, such as packing rooms, are used.

A5-003

Bunding is used where necessary to meet the requirements of dangerous goods and environment protection
legislation.

A5-004

Where high volume materials (eg solvents in 200 litre drums) are stored out-doors, they are in adequately sealed
containers and outside storage conditions are unlikely to adversely affect their quality.

A5-006

Manufacturing processes that involve the application of a liquid premix onto an inert carrier powder ensure
adequate dispersion of the liquid and, therefore, the active ingredient(s). Mixing times and methods ensure batch
homogeneity.

A5-007

Measures are in place to prevent cross-contamination from hoses, fixed pipe-work and connections

Minor
non
conformance

Major
non
conformance

Not
Audited

Key observations and comments (Comment on both positive and negative aspects of Ectoparasiticide manufacture. Record evidence sighted and reviewed, such as
SOPs, records, observations, etc, particularly with respect to non-conformance) .

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ANNEX 6

KP80_F33

PREMIXES, SUPPLEMENTS AND BIOLOGICAL FEED ADDITIVES

Check
Point No.

Checkpoint

Acceptable

A6-001

The manufacture of dry premixes and supplements is carried out in dedicated areas that are separated from other
aspects of veterinary chemical manufacture either by distance or by physical barriers, in order to minimise the risk
of cross-contamination.

A6-002

Cleaning programs specifically address the buildup of dust, sticky materials such as molasses, and corrosive
materials such as salt.

A6-003

An effective pest control program is in place.

A6-004

External driveways and paths surrounding the manufacturing area are sealed to prevent the tracking of dirt and
other external contaminants on the wheels of forklifts and other mobile equipment into the production areas.

A6-005

Where premixes and supplements are manufactured in premises also used to manufacture other products, the staff
involved in the manufacture of premixes and supplements are clearly identified and trained in those elements of
GMP appropriate to their need.

A6-006

Complete cleaning of equipment may not be required between batches of the same or closely related products,
provided that product integrity is maintained.

A6-007

Parts of the process likely to have a significant adverse influence on the stability of the active ingredients (eg use
of steam in pellet manufacture), are controlled to ensure batch-to-batch consistency.

A6-008

Special attention is paid to the prevention of microbial contamination during manufacture or storage of susceptible
liquid formulations.

Minor
non
conformance

Major
non
conformance

Not
Audited

Mined mineral supplements

The identity of mined material is checked by appropriate means.
Stockpiled material is protected from contamination by storm-water run-off and other environmental
contaminants.
Steps are taken to ensure that bagged material is free from contamination such as pieces of metal, broken glass,
bird droppings, etc.

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Direct-fed microbials and enzyme products

Check
Point No.

Checkpoint

Acceptable

A6-009

The air supply to the areas used for the production of direct-fed microbials and enzyme products is designed to
minimise contamination.

A6-010

Personnel responsible for the manufacture and quality of direct-fed microbials and enzyme products have
appropriate qualifications in microbiology or related subjects and/or experience in the manufacture of such
products.

A6-011

Where manufacture of direct-fed microbials and enzyme products is carried out in premises also used to
manufacture other products, the staff involved in the manufacture of direct-fed microbials and enzyme products
are clearly identified and trained in those elements of GMP appropriate to their need

A6-012

The taxonomic identity of microorganisms selected for direct-fed microbials or enzyme production is checked.

A6-013

Master seed cultures are checked for identity by morphological characterisation and comparison with the
taxonomic characteristics originally identified. Their purity is checked before transfer to the fermentation
equipment by serial dilution, plating and macroscopic and microscopic inspection for any foreign microorganisms.

A6-014

Master seed cultures are maintained in such a way as to minimise degeneration and maintain genetic stability.

A6-015

All seed cultures are clearly labelled and strict aseptic techniques applied in revival and subculture.

A6-016

All operations are designed to avoid contamination, formation of undesirable by-products, deterioration and
handling errors.

A6-017

Culture liquids are sampled and checked for purity at regular intervals throughout the fermentation process.
However, in semi-solid surface cultivation, purity control may be restricted to visual inspection.

A6-018

Enzyme activity and operational parameters such as temperature, pH and oxygen content, are monitored during
fermentation and kept within predetermined ranges based on experience. Deviations from these ranges may
indicate a contamination before it can be detected in microbial assays.

A6-019

Steps are taken to ensure that contamination of the product during recovery is minimised.

Minor
non
conformance

Major
non
conformance

Not
Audited

Key observations and comments (Comment on both positive and negative aspects of the manufacture of Premixes, Supplements and Biological Feed Additives.
Record evidence sighted and reviewed, such as SOPs, records, observations, etc, particularly with respect to non-conformance) .

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