The agreement must indicate which controlled and documented changes can be made by the contractor only with notification to the owner and those that must be discussed, verified and approved by the owner before they can be implemented. In the draft guidelines, the FDA defined an owner as each party that ”introduces (or causes) the introduction of a drug into intergovernmental commerce. As we said in our previous article, this definition was so broad that it seemed highly unlikely that the FDA would actually intend to apply the guidelines to all entities that would meet that definition (for example. B distributors). Not only did it seem illogical to require distributors or other ”owners” in effluents to be responsible for certain non-delegable cGMP requirements, such as product release, but it should also have resulted in the repeal of Section 303 (c) of the Act authorizing down stream companies to rely on written product warranties from Up Stream manufacturers. The FDA`s current position on quality agreements is outlined in the ”Contract Manufacturing Arrangements for Drugs: Quality Agreements” guidelines published in 2016. The guidelines expressly state that production activities are the most important element of a quality agreement. It focuses on the seven most important areas that should be addressed in a quality agreement and their specific impact on the quality and control of change. To learn how to optimize the coordination of quality agreements and other order manufacturing functions with digital tools, read the trend letter ”3 Ways Contract Manufacturing Organizations Are Looking to Digital Technology to Improve Collaboration.” The agreement should not include such elements as terms and conditions, pricing and stair terms, forecasts, delivery conditions, confidentiality obligations and liability limitations. These items are included in the delivery agreement, which is a separate document. The quality agreement can be included in the reference supply agreement. If both documents are drawn up in one document, the authorization list may contain individuals who have no reason or time to check for problems that have nothing to do with their area of expertise. There are four types of quality agreements: manufacturing, supplier, supplier and quality of service agreements, which are tailored to the relevant aspects of the type of relationship.
The term ”manufacturing” within the meaning of this document includes processing, packaging, thinking and labelling, quality testing and operations Unit.No subject matter whose activities are outsourced, the quality entity of the contracting entity (”owner”) remains ultimately responsible for the approval and refusal of drugs manufactured by the contract manufacturer (21 CFR 210.3 (12)). This is not the case in Europe, where authorisation (certification by a qualified person) can also be outsourced. Chapter 7 of the EU PSD provides for quality agreements defining the responsibilities of the contractor and contractor. ”The drafting and analysis of contracts must be defined, accepted and controlled.” Chapter 7 also defines the preparation of contracts with respect to the area of responsibility.