Skip to main content Skip to search Skip to main navigation

EMA: Public Consultation on Remote Batch Certification

The EMA has published a four-page consultation document in the form of Q&As concerning the physical attendance and the place of a personal residence of a Qualified Person on 11 May 2022. The guidance states that the work of a QP must be adapted to current standards to enable remote certifications without a QP being present at the site. A public consultation is possible until 13 June 2022.

The Q&A is based on the fundamentals of the EU GMP Guidelines, in particular those of Annex 16, and is applicable to EU/EEA QP certification or QP confirmation. It applies to the production and importation of human and veterinary medicinal products as well as investigational medicinal products. Following is a brief summary of the four Q&As:

Is remote batch certification / batch confirmation by the QP (i.e. when not at the authorised site address specified on the MIA) allowed on a routine basis?

This could be acceptable if a remote certification is accepted by the national authority at the site. The manufacturer and the qualified person should meet all valid local requirements.


Where remote QP certification / confirmation is allowed on a routine basis, what conditions should apply?

Broadly summarised, they include

  • full compliance of the remote certification with EU legislation and EU GMP guidelines
  • a certification that must take place within the EU/EEA in any case
  • adequate documentation and control within the quality system when remote certification is used on a routine basis
  • electronic access to any information required for QP according to Annex 16 EU GMP Guidance. All IT systems must comply with the requirements of EU-GMP Annex 11
  • The availability of all performed measurements for inspection purposes by the competent authorities.

Is the QP required to be a resident in the Member State where the authorised site is located?

Reference is made to the specific national requirements


What are the technical requirements for the remote access and the signature used for batch certification / confirmation?

In terms of IT security and data integrity, the risk for remote access is higher than for access within the controlled environment at the approved site. The minimum requirements are highly dependent on the state of the technology and should be consistent with the guidelines of Annex 11. For instance, among other things:

  • Recognized industry standards should be used for authentication and authorization (e.g., two-factor or multi-factor authentication)
  • Security parameters on the network operating system, database, and application layer of the QP should be configured adequately
  • data should be secured using a high-level of transport encryption
  • the MIA holder must ensure that only the QP is able to perform remote certification/confirmation of batches

Source:

EMA: Public Consultation Concerning The Physical Attendance And The Location Of Personal Residency Of The Qualified Person

Meet the GMP Compliance Adviser

The GMP Compliance Adviser is the world's largest knowledge portal for quality management in the pharma business. 

The demo access is non-binding and ends automatically.

Test it now for free

You may also be interested in the following articles:

How is a QRM process initiated?

How is a QRM process initiated?

You can view the answer here:
Read more
FDA: Updated Pre-RFD Guidance for Combination Products

FDA: Updated Pre-RFD Guidance for Combination Products

The U.S. FDA has released an updated final guidance on preparing a Pre-Request for Designation (Pre-RFD), replacing the previous 2018 version. The revised document provides new recommendations for interacting with the Office of Combination Products (OCP) and clarifies expectations for Pre-RFD submissions.
Read more
EDQM: 9 Virtual Training Modules on Ph. Eur. and CEPs

EDQM: 9 Virtual Training Modules on Ph. Eur. and CEPs

The EDQM has introduced a modular training programme covering chemically defined active substances and medicinal products. It will take place between 1 and 12 December 2025.
Read more
 Data Integrity and Data Governance

Data Integrity and Data Governance

Data integrity is a key element in the pharmaceutical quality assurance system which has gained importance in recent years, especially from the viewpoint of the authorities. In GxP-regulated companies, managers are responsible for identifying and minimising risks to data integrity (“data governance”).

Read more
EMA Clarifies “Novel or Complex Manufacturing Process” Definition

EMA Clarifies “Novel or Complex Manufacturing Process” Definition

In its Quality of Medicines Q&A – Part 1, the EMA has clarified how “novel or complex manufacturing processes” should be interpreted for variation categories Q.II.b.1 (new/replacement finished product manufacturing site) and Q.II.b.4 (change in batch size).
Read more
EU: Environment Committee Comments on EU Regulation Regarding Critical Medicines

EU: Environment Committee Comments on EU Regulation Regarding Critical Medicines

The Environment Committee of the European Parliament has issued its opinion on the proposed EU Regulation to strengthen the availability of critical medicines. Key recommendations include fast-track permitting, simplified environmental assessments, and support for strategic manufacturing projects to boost EU production capacity.
Read more
Previous
Next