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1
2-6
Sampling according to WHO guidelines for
sampling of pharmaceutical products and related
materials
Marta Miquel
Interregional Seminar for Quality Control
Laboratories involved in WHO Prequalification
Programme and/or participating in respective
sampling and testing projects, Nairobi, Kenya,
23-25 September 2009
2
WHO sampling guideline - Introduction
  • This guideline is primarily addressed to
    governmental organizations such as drug
    regulatory authorities (including inspectorates),
    quality control laboratories, customs and police
    officials, when surveying the national markets
    for the quality of drug products.
  • The guideline is available on the internet as
    Annex 4 of the WHO Technical Report Series No.
    929 (2005), issued by the WHO Expert Committee on
    Specifications for Pharmaceutical Preparations.
  • http//apps.who.int/prequal/info_general/documents
    /TRS929/WHO_TRS_929.pdf

3
  • Before sampling
  • purpose of sampling?
  • type of tests intended to be applied to the
    samples?
  • type of products/materials to be sampled?
  • are sampling facilities adequate?
  • are responsibilities of the samplers clear?
  • Note these topics are dealt with in the
    presentation
  • Organisation of sampling programmes background
    information

4
  • Sampling process
  • Preparation for sampling
  • Sampling operation
  • Sample storage and retention

5
I - Preparation for sampling
  • Sampling tools should be available to the
    sampler, e.g. to open containers (knives,
    hammers,...), material to reclose the packages
    (sealing tape), self-adhesive labels to indicate
    that some of the contents have been removed,
    etc...
  • Sampling tools should be made of inert materials
    (e.g. polypropylene or stainless steel avoid
    glass) and kept very clean. After use, thoroughly
    washed, rinsed with water or suitable solvent,
    dried and stored in clean conditions.
  • Disposable sampling materials can also be used.
  • Washing facilities should be located in, or close
    to, the sampling area.
  • Cleaning procedure should be documented and
    validated ( demonstrated efficiency).
  • Sterile pharmaceutical products should be sampled
    under aseptic conditions.

6
  • Examples of types of sampling tools (Appendix 1
    of WHO guideline)

Dip tubes for liquids
Spatulas for solids
Sample thieves for solid samples in deep
containers
Bag-sampling spears for taking samples from bags
7
II - Sampling operation
  • Written sampling procedure operations to be
    performed on a defined material for a specific
    purpose, including health/safety aspects (see
    Appendix 3 of WHO guideline Examples of steps to
    be considered for inclusion in a SOP).
  • Sampling plan description of the location,
    number of units and/or quantity of material that
    should be collected, and associated acceptance
    criteria.
  • Make sure that representative samples are taken
    in sufficient quantity. Representative sample
    sample obtained according to a sampling procedure
    designed to ensure that the different parts of a
    batch or the different properties of a
    non-uniform material are proportionately
    represented.
  • Samples should never be returned to the bulk.

8
II - Sampling operation (cont.)
  • Sampling operations should be supervised and
    documented gt sample collection form gt always
    kept together with the collected sample.
  • Sample collection form written record of the
    sampling operations, containing batch number,
    sampling date/place, reference to sampling
    protocol used, description of containers and
    materials sampled, possible abnormalities, any
    relevant observations, name/signature of the
    sampler...
  • Store the sample in a properly labelled
    container sample type, name of material,
    identification code, batch number, code,
    quantity, date of sampling, storage conditions,
    handling precautions, container number....

9
Example of sample collection form (Appendix 2 of
WHO guideline)
Page 2
Page 1
10

II - Sampling operation (cont.)
  • Pay attention to any signs of non-uniformity of
    the material
  • Differences in shape, size, colour of particles
    in crystalline/granular/powdered subst.
  • Moist crusts on hygroscopic substances.
  • Solid deposits in liquids or semi-liquids.
  • Stratification of liquids.
  • In this case, sample portions of the material and
    test them separately from the material with
    normal aspect.
  • Take into account previous experience with the
    product and supplier.

11
III Sample storage and retention
  • Containers
  • Containers used to store a sample should comply
    with the storage directions for the active
    pharmaceutical ingredient, excipient or drug
    product
  • should not interact with the sampled material.
  • should not allow contamination.
  • should protect the sample from light, air and
    moisture.
  • should be sealed and adequately labelled.
  • avoid mix-up when containers are opened (screw
    caps, separate lids).
  • manipulations/unauthorised opening should be easy
    detectable.
  • transported in such way as to avoid breakage.

12
III Sample storage and retention (cont.)
  • Rooms for sample storage
  • Security and adequate storage conditions (light,
    ventilation, safety requirements, and any special
    requirements) should be ensured for the rooms in
    which samples are stored.
  • Samples should be stored according to the storage
    conditions as specified for the respective API,
    excipient or drug product.
  • Packaging materials similar to those in which the
    bulk is supplied should be used for long-term
    storage.

13
Examples of types of containers used to store
samples of starting materials and bulk products
(Appendix 4 of WHO guideline)
Bag for storage of samples
Screw-top containers
14
  • Sampling for regulatory issues
  • Drug quality surveillance programmes
  • Inspections

15
I - Drug quality surveillance programmes
  • The extent of the routine surveillance programmes
    for drug quality, carried out by National Drug
    Regulatory Authorities will depend on
  • capacity of the national drug QC lab
  • extent to which the quality of the product has
    been assessed prior to registration
  • extent to which the requirements for GMP are
    implemented
  • number of products imported from abroad
  • The programme should include marketed products,
    whether registered for sale or prepared in
    pharmacies.
  • Each product should be assessed regularly (every
    2-3 years).
  • Particular attention to products of prime
    importance to public health programmes or
    potentially dangerous, unstable or difficult to
    formulate properly.

16
I - Drug quality surveillance programmes (cont.)
  • The responsible laboratory should prepare the
    sampling programme (if needed under the guidance
    of the drug regulatory authority) every year or
    half a year.
  • Sampling programme
  • Lists the products to be sampled during a given
    period
  • Specifies the sampling procedure
  • Specifies the size of the samples to be collected
    (including retention sample)
  • States to what extent each brand of a given
    product will be sampled
  • States which local authority or inspector will be
    responsible for sampling
  • Indicates to which laboratory each sample should
    be sent (if more than 1)

17
II - Inspections
  • Inspectors may take samples from
  • retail or hospital pharmacies (including
    preparations manufactured in bulk in the
    premises)
  • industry
  • wholesalers
  • In case of a complaint received about a product,
    the sample should include the original container
    and if possible 1 or 2 unopened containers with
    the same batch number.
  • In case of deteriorated dosage forms, the sample
    should consist of one or more containers showing
    visual signs of deterioration.

18
  • Sampling for acceptance
  • Starting materials
  • Intermediates in manufacturing and bulk products
  • Finished products
  • Packaging materials

19
I Sampling of starting materials
  • Uniform material sample can be taken from any
    part.
  • Non-uniform material
  • Special sampling tools are needed.
  • Alternatively, if applicable, restore uniformity
    before sampling (e.g. stratified liquid may be
    stirred or a solid deposit in a liquid may be
    dissolved by gently warming and stirring)
    validated method !
  • In these cases, in order to prepare
    representative samples, see ISO 2859.
  • Partially processed natural products (animal,
    herbal and mineral) should be treated as
    intrinsically non-uniform. For info, sampling of
    herbal drugs, see European Pharmacopoeia chapter
    2.8.20.

20
II - Sampling of intermediates in manufacturing
and bulk products
  • Intermediates liquids and semi-solid products
    powdered solids or granulates unit dosages forms
    in bulk (tablets, capsules).
  • Pay attention to the segregation of bulk
    materials during transportation.
  • These products may be assumed as uniform if the
    transportation process has been validated, AND
  • They are labelled with name of the manufacturer
    and a single batch number
  • They have been produced according to GMP and
  • They are supplied with a certificate, issued in
    the country of origin, according to the WHO
    Certification Scheme on the quality of
    pharmaceutical products moving in international
    commerce

21
  • WHO Certification Scheme for Products moving in
    International Commerce is an international
    voluntary agreement, created to enable countries
    with limited drug regulatory capacity to obtain
    partial assurance from exporting countries
    concerning the safety, quality and efficacy of
    the products they plan to import.
  • http//www.who.int/medicines/areas/quality_safety/
    regulation_legislation/certification/en/
  • On this website you can find information about
  • competent authorities participating in this
    certification scheme.
  • model certificate of a pharmaceutical product.
  • guidelines on the implementation of this
    certification scheme.

22
III - Sampling of finished products
  • Uniformity a single consignment of a product
    from a single manufacturer and labelled with a
    single batch number may be assumed to be uniform.
  • The minimum size of the samples to be taken is
    determined by the requirements of the analytical
    procedure used to test the product (tests of unit
    dosage forms for uniformity of weight, volume or
    content, or sterility tests can require a large
    number of samples).
  • Sampling and testing may be adjusted according to
    the experience with the source of the product,
    e.g. manufacturer or supplier.
  • Consignment quantity of a bulk starting
    material or drug product, made by one
    manufacturer or supplied by one agent, supplied
    at one time in response to a particular request
    (1 or more containers, 1 or more batches).

23
IV - Sampling of packaging materials
  • Pay attention to mixing up printed packaging
    materials during sampling
  • only 1 material should be handled at a time.
  • adequately protect and identify the sample.
  • Samples of packaging materials should never be
    returned to the consignment.
  • During sampling, primary packaging materials
    should be protected against environmental
    contamination (e.g. special measures when
    sampling parenteral ampoules).

24
IV - Sampling of packaging materials (cont.)
  • A consignment of packaging materials may NOT be
    considered homogeneous if
  • Materials manufactured on different days or
    machines
  • Materials manufactured on one machine, but
    different stations (e.g. printing stations,
    moulding stations)
  • Packaging manufactured with different source
    materials
  • Change in quality during the process (colour
    variation, text legibility or change of printing
    plate, container-wall thickness...)
  • Important to take random samples from across the
    consignment.
  • Consider focus sampling based on the
    abovementioned risk factors.

25
  • Sampling plans
  • Starting materials
  • Finished products
  • Packaging materials
  • Note guideline primarily addressed to Drug
    Regulatory Authorities, these sampling plans
    might not be appropriate for manufacturers.
  • The following plans are examples

26
Sampling plans for starting materials
  • n-plan
  • p-plan
  • r-plan

See examples of use of sampling plans in Appendix
5 of WHO guideline
27
I The n-plan
  • Only used when material is considered uniform and
    from a recognised source.

N sampling units in the consignment (e.g.
individual package, drum or container)
  1. Calculate n (n units to be sampled).
  2. Select at random n units from N.
  3. Take a sample from these units.
  4. QC lab checks appearance identity of each
    sample.
  5. If results concordant gt combine samples into a
    single final sample.
  6. Take analytical sample for full testing.
  7. Keep the rest as retention sample.

e.g. N40 gt n7 (units to be sampled)
28
  • NOTES
  • The n-plan is NOT statistically based and
    should be used only as a guiding principle.
  • The n-plan is NOT recommended for use by
    control laboratories of manufacturers that are
    required to analyse and release or reject each
    received consignment of the starting materials
    used to produce a drug product.

29
II The p-plan
  • May be used when material is considered uniform,
    from a recognised source and the main purpose is
    to test for identity.

N sampling units in the consignment (e.g.
individual package, drum or container)
  1. Sample each of the N sampling units.
  2. QC lab checks appearance identity of each
    sample.
  3. If results concordant gt p final samples are
    formed by appropriate pooling.
  4. Keep the p samples for retention (or full testing
    if required).

e.g. N40 gt p3 (final samples after
testingpooling)
30
III The r-plan
  • May be used when material is considered
    non-uniform and/or obtained from a not well know
    source.
  • Can be used for herbal medicinal products used as
    starting materials.

N sampling units in the consignment (e.g.
individual package, drum or container)
  1. Sample each of the N sampling units.
  2. QC lab checks appearance identity of each
    sample.
  3. If results concordant gt r samples are randomly
    selected.
  4. r samples individually fully tested.
  5. If results concordant gt combine the r samples
    for the retention sample.

e.g. N40 gt r10 (randomly selected samples for
testing)
31
Sampling plans for packaging materials
  • Should be based on defined sampling standards
    such as
  • ISO 2859
  • British Standard BS 6001-1
  • ANSI/ASQ Z1.4-2008 (American National Standards
    Institute/American Society for Quality)

32
Sampling plans for finished products
  • Should be based on defined sampling standards
    such as
  • ISO 2859
  • British Standard BS 6001-1
  • ANSI/ASQ Z1.4-2008 (American National Standards
    Institute/American Society for Quality)
  • In some cases a visual inspection might be
    sufficient.
  • However, if physical and chemical testing is
    required, the sampling units should consist of
    whole packs (individual packs should not be
    broken open).

33
ISO 2859 series - Sampling procedures for
inspection by attributes
  • ISO 2859-11999 - Part 1 Sampling schemes
    indexed by acceptance quality limit (AQL) for
    lot-by-lot inspection
  • ISO 2859-21985 - Part 2 Sampling plans indexed
    by limiting quality (LQ) for isolated lot
    inspection
  • ISO 2859-3 - Part 3 Skip-lot sampling procedures
  • ISO 2859-42002 - Part 4 Procedures for
    assessment of declared quality levels
  • ISO 2859-52005 - Part 5 System of sequential
    sampling plans indexed by acceptance quality
    limit (AQL) for lot-by-lot inspection

34
Practical example
  • Sampling documentation used in the Austrian Food
    and Drug Agency AGES (Vienna, Austria
  • http//www.ages.at

35
Step 1 Sampling order from a scientific
advisor Step 2 Verification and authorization of
order Step 3 Assignment to authorized sampling
staff
1 ordering department 2 date / name of
scientific advisor 3 urgent / planned beginning
of analysis 4 requested sampling site 5 on
site sampling necessary 6 specific information
for transport/storage 7 name of sample 8
MA-number 9 batch number 10 quantity 11
unit 12 signature of head of dep.
1
4
2
5
3
6
10
9
8
7
11
12
36
Step 4 Sampling request sent by fax
37
sampling performed onsite
Part 1

1 sample (name, strength, dosage form) 2 number
of packages, units, quantity of samples 3 batch
number 4 expiry date 5 MA-number 6
manufacturing date 7 place of withdrawal
(company, wholesaler, pharmacy, others) 8
sampling by company official expert official
inspector public health officer
1
2
3
5
6
4
7
8
38
Part 2

1 found storage conditions 2 light
protection 3 temperature 4 cause for
suspicion 5 prohibition of sale 6 crosscheck 7
sealing executed 8 certificate of analysis 9
composition/formulation 10 date of
withdrawal/signature
1
2
3
4
5
6
7
8
9
10
39
Step 5 Arrival of sample
1 general information name, MA-number, date of
receipt, 2 receipt control - temperature 3
storage conditions 4 sample damaged (yes/no)
1
2
3
4
40
References
  • WHO guidelines for sampling of pharmaceutical
    products and related materials. Annex 4 of WHO
    Technical Report Series No. 929 (2005).
  • ISO 2859 - Sampling procedures for inspection by
    attributes.
  • British Standard BS 6001-1 - Sampling procedures
    for inspection by attributes.
  • ISO 107252000 - Acceptance sampling plans and
    procedures for the inspection of bulk materials.
  • Good Manufacturing Practices Part I - Basic
    Requirements for Medicinal Products Part II -
    Basic Requirements for Active Substances used as
    Starting Materials.
  • European Pharmacopoeia. Chapter 2.8.20. Herbal
    drugs sampling and sample preparation.
  • ANSI/ASQ Z1.4-2008 Standard (American National
    Standards Institute/American Society for Quality)
    - Sampling Procedures and Tables for Inspection
    by Attributes.

41
http//www.edqm.eu
  • Thank you for your attention

Marta Miquel Scientific Officer Council of
Europe European Directorate for the Quality of
Medicines and HealthCare (EDQM) Biological
Standardisation, OMCL Network HealthCare
Department (DBO) 7 Allée Kastner, CS 30026 F-
67081 Strasbourg, France Tel. 33 (0) 3 90 21
42 41 Fax 33 (0) 3 88 41 27 71 E-mail
marta.miquel_at_edqm.eu
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