Who Is The Marketing Authorisation Holder?Firstly, the MAH is the company or legal entity in whose name the Marketing Authorisation has been granted. It should be noted that the way in which a MAH is expected to interact with the registered manufacturing sites in a specific marketing authorisation is not clearly laid out in specific guidance. Therefore, it is crucial that the MAH understands their role and responsibility in facilitating GMP compliance at all outsourced manufacturing sites. These roles and responsibilities include:
- The MAH should ensure that documented agreements and robust communication process are in place between the MAH and the contractor.
- The definition and management of the necessary documents and procedures must fall within the scope of their quality management system.
‘Delegate Activities, Not Responsibility’It is very important for companies to understand that the MAH can ultimately delegate activities but not responsibility. Outsourcing of manufacturing and other activities is ever increasing across the pharmaceutical sector. This has been driven, in part, by mergers and acquisitions. However, as changes happen, we have found, in our experience, that issues get ‘missed’. To ensure that issues do not get forgotten, we always advise that there is a need to deepen working relationships with specific government and health agencies. Outsourcing brings with it many benefits, such as improved processes and standards across the industry through the spread of knowledge and technology globally. However, if the supply chain becomes too complicated the MAH oversight of processes can be reduced significantly. The lack of supply chain oversight means it can be more difficult to manage and assess the entire supply chain. This increases risks including quality non-compliances.
3 Quality Risks To ConsiderIn situations such as this, experience has taught us that there are 3 quality risks:
- Data integrity issues at supplier plants
- Issues with regulatory oversight and communication of regulatory updates across all sites.
- Inadequate Quality agreements due to the lack of understanding of roles and responsibilities
9 Issues To ConsiderWe have considered the tasks that need to be completed, and below we are highlighting 9 issues that should be considered by companies acquiring/involved in a merger or similar:
- Lack of supply chain gap analysis, leading to gaps in supply chain knowledge
- Reduction in the frequency of supplier assessments
- Insufficient resources available to properly manage quality issues
- Poor management of materials e.g. cold chain and supplier GMP oversight
- Inadequate communication and sharing of important quality information between MAH and suppliers
- To improve MAH oversight of the entire supply chain:
- Adequate resources and processes should be available to control all outsourced activities.
- Regular on-site audits of all suppliers and contractors must be conducted
- Regular review of all suppliers and appropriate records maintained
ConclusionIf embarking on a merger or if your company is acquiring another company, it is useful to remember the following points:
- Adequate supplier and quality agreements must be in place with all contractors.
- The agreements must clearly define the agreed roles and responsibilities of all parties.
- The agreement must also detail how information/Issues are communicated between parties to prevent any delays in the sharing of important information.
- To prevent problems in future operations it is vital that enough time and resources are spent on selecting affiliates and partners for outsourcing. The decision should be based on quality and not solely on the associated cost.
- When selecting companies to partner with on projects it is also useful to consider the ‘pain points’ that might arise.
- Language barriers often arise during a project as the issue has often not been considered in the evaluation of suppliers. While this might sound like a simple mistake, it is quite common. Our experience has shown us that early engagement between the key stakeholders involved in the project from the client side with the project personnel on the supplier side is critical to the success of the project. Doing so enables both parties to better plan projects.
- MAH lack of understanding of the National Regulations in the ROW country and the affiliates lack of understanding of EU requirements.
- Can you or your regulatory partner build a trusting relationship with the company and agency.