So far, in such cases, a statement of non-compliance is the outcome of the risk-assessment of GMP-compliance of an inspected site. Following the principles of ICH Q9, the concerned member states subsequently have to decide how to manage the risk (recall, prohibition of supply, suspension of MIA etc.). Where those actions might lead to shortages of critical medicines in a particular member state of the European Union, the competent authority of that member state might decide to mitigate and accept the risk. However, this risk acceptance does not change the initial risk-assessment; the site will remain non-compliant until satisfactory corrective actions are taken.
With this consultation, the EMA aims at collecting relevant information from stakeholders to help the GMP/GDP Inspectors Working Group to develop an effective and harmonised risk-based approach for dealing with the supply of critical medicines in case of serious GMP non-compliance. As a result, the outcome shall then amend the compilation of community procedures and exchange of information (CoCP) by:
The document, including the updated “Statement of non-compliance with GMP” is open for public consultation until 15 May 2018. Please refer to the original paper for more details on this.