A-116

Ensuring Identity Purity Strength and Composition of Solid Dosage Finished Products

Section A — General and Personnel Revision 7 14 pages

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1.0 Purpose 
 
 The purpose of this procedure is to describe all stages of manufacturing, packaging, labeling,
 testing and holding of Solid Dosage Form Finished Products to ensure their identity, purity,
 strength, and composition. 
 
 2.0 Scope 
 
 This procedure applies to all Solid Dosage Finished Products manufactured at Ion Labs, Inc.
 
 3.0 Responsibility 
 
 3.1 It is the responsibility of all departments — Production, R&D, QA, QCS, QCL,
 Purchasing, Shipping, and Receiving to strictly follow this procedure.
 
 4.0 Definitions 
 
 4.1 Identity — A specific unique characteristic of a product; a positive match (complies)
 between an established/standardized characteristic and a finished product attribute
 
 4.2 Purity — Absence of impurities 
 
 4.3 Strength — Concentration of listed component 
 
 4.4 Composition — Appropriate list of ingredients and components in finished product
 
 4.5 Quality — Means that the finished product consistently meets the established
 specifications for identity, purity, strength and composition, and has been
 manufactured, packaged, labeled, tested, and held under conditions to prevent
 
 adulteration 
 
 46 QCS-— Quality Control/Systems 
 
 4.7. LC- Label Control 
 
 4.8 R&D -— Research and Development 
 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 2 of 14 
 Composition of Solid Dosage Finished Products 
 
 4.9 PO — Purchase Order 
 
 4.10 CoA — Certificate of Analysis 
 
 4.11 RMP — Raw material profile 
 
 4.12 RMID — A unique identifying number assigned to each raw material 
 
 4.13 R# — A unique identifying number assigned to individual batches of raw materials upon
 receipt 
 
 4.14 RMSTT — Raw Material Specification and Test Ticket - A document that lists
 test methods, specifications, results and information for each unique raw material
 
 4.15 MBR — Master Batch Record — a compilation of documents and forms that
 identifies all of the pertinent instructions, process, and specifications necessary
 
 to manufacture a product 
 
 4.16 BPR — Batch Production Record - an accurate reproduction of the MBR issued to
 production | 
 
4.17 Product Profile — Establishes a products components, in-process, finished

 product specifications, and stability which ensure the identity, purity, strength, and
 composition ofthe product 
 
 4.18 FPTT — Finished Product Test Ticket; an internal CoA 
 
 CCP — Critical Control Point - a point during production of a product at which
4.19 controls are applied and adherence to specification is determined prior to proceeding

 IAV — Ingredient, Addition, Verification Form- Document containing
4.20 specifications associated with label claim support

 4.21 OTC — Over the counter drug product 
 
 4.22 RMTS — Raw Material Testing Summary 
 
 5.0 References 
 
5.1 A-108, SOP, Good Manufacturing Practices and Personal Hygiene

 3.2 B-703, SOP, Solid Coating Pan 
 
 5.3 B-704, SOP, Perforated Pan Coating 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page3 of 14 
 
 Composition of Solid Dosage Finished Products 
 
 5.4 B-901, SOP, Weighing and Blending Procedure 
 
 5.5 B-902, SOP, Compression Procedure 
 
 5.6 B-903, SOP, Encapsulation Procedure 
 
 5.7 B-904, SOP, Packaging Procedure 
 
 5.8 B-905, SOP, Quality Control Inspection Process 
 
 5.9 C-103, SOP, Batch Production Record Review and Release of Finished Product
 
 5.10 C-104, SOP, Master Batch Record and Issuance of Batch Production Record
 
 5.11 C-603, SOP, New Product Realization Process 
 
 5.12 C-707, SOP, Critical Control Point Specifications 
 
 5.13 D-105, SOP, Out of Specification/Out of Trend Investigation 
 
 5.14 D-403, SOP, Calculations for Ingredient Addition Verification for Finished Products.
 
 5.15 D-901, SOP, Raw Material Life Cycle 
 
 5.16 D-902, SOP, Establishment of Specifications 
 
 5.17 E-204, SOP, Receiving Process for Raw Materials 
 
 5.18 E-601, SOP, Vendor Qualification 
 
 5.19 E-702, SOP, Finished Product Sampling Procedure 
 
 5.20 E-703, SOP, Raw Material Sampling Procedure 
 
 5.21 E-704, SOP, AQL Statistical Sampling Plan 
 
 5.22 E-802, SOP, Quarantine of Materials 
 
 5.23 21 CFR Part 111 
 
 5.24 21 CFR Part 211 
 
 5.25 21 CFR Part 700 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 4 of 14 
 Composition of Solid Dosage Finished Products 
 
 6.0 Procedure 
 
 6.1 Purchasing of Raw Materials 
 
 6.1.1 All raw materials used in the manufacturing of OTC must be purchased from
 qualified suppliers, approved by Ion Labs and must be listed on the Approved
 
 Vendors List as per SOP E-601 Vendor Qualification. 
 
 6.2 Receiving, inspection, sampling, testing, and release of Raw Materials
 
 6.2.1 Receiving of Raw Materials 
 
 6.2.1.1 Purchasing will make available in Batchmaster approved POs to
 warehouse personnel. 
 
 6.2.1.2 The warehouse associate compares incoming materials to the
 
 packing list and Batchmaster item description. The warehouse will
 quarantine material that does not match the PO for quality, grade, or
 vendor. Material will also be quarantined if packaging is damaged.
 Quality will be notified of the discrepancy and determine the
 
 suitability of the material. 
 
 6.2.1.3 Warehouse associate assigns a sequential number in the format of
 R00001 to each incoming raw material, creates a label containing the
 RMID, raw material name, R number, vendor name, and vendor lot
 number for the raw material container, and applies to each bulk
 container of raw material (refer to SOP D-901 Raw Material Life
 
 Cycle, SOP E-204 Receiving Process of Raw Materials, and SOP E-
 802 Quarantine of Materials). 
 
 6.2.2 Inspection and Sampling of Raw Materials 
 
 6.2.2.1 QC samples raw materials according to SOP E-703 Sampling of
 Raw Materials and E-704 AQL Statistical Sampling Plan.
 
 6.22.2 The samples will be delivered to the lab for analysis and logged
 into the QC laboratory sample log book (Refer to SOP E-703
 Sampling of Raw Materials). 
 
 6.2.3 Testing and Release of Raw Materials 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 5 of 14 
 Composition of Solid Dosage Finished Products 
 
 6.2.3.1 QC Lab completes the testing of raw materials as outlined in the RMP
 based on the COA Challenge Status, and documents the results on the
 RMTS (refer to SOP D-901 Raw Material Life Cycle). 
 
 Note: Data generated for the first component of a partial shipment can be
 used for the second component release in instances when partial
 
 shipments are received, each with the same manufacturer lot # and
 separate R#s are generated. A separate RMTS will be generated for the
 second component of the partial shipment for tracking purposes.
 
 6.2.3.1.1 Raw materials that meet the release specifications
 
 listed in the RMP can be processed for release. QC
 lab updates the raw material status in Batchmaster to
 “Released”. (Refer to SOP D-901 Raw Material Life
 Cycle and SOP E-802 Quarantine of Materials/ 
 Products). 
 
 Note: All approved RMs that are used in Ion Labs
 products are subject to CofA challenges as defined
 in D-901 Raw Material Life Cycle and must pass
 verification testing if the RMs are to be used in
 Ion products. All raw materials require three CoA
 
 challenges before reduced testing can be 
 implemented. 
 
 6.2.3.1.2 For raw materials that do not meet the release
 specifications listed in the RMP, the QC lab will
 update the raw material status in Batchmaster to
 
 “Hold” until a final disposition has been made by
 Quality Management. (Refer to SOP D-105 Out of 
 Specification/ Out of Trend Investigation and SOP E-
 802 Quarantine of Materials/Products). 
 
 6.3 Production and Process Control System 
 
 6.3.1 Master Batch Record and Issuance of Batch Production Record 
 
 6.3.1.1 R&D creates Product Profile, prepares the Master Formula,
 Weighing & Blending Instructions, and supplement facts sheet for
 each unique formula to ensure uniformity in the finished batch (refer
 to SOP C-603 New Product Realization Process). 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 6 of 14 
 Composition of Solid Dosage Finished Products 
 
 6.3.1.2 The BPR issued to production, accurately follow the appropriate
 MBR and all steps in the manufacturing of the batch (Refer to SOP
 C-104 Master Batch Record and Issuance of Batch Production
 Record). 
 
 6.3.2 Manufacturing Operations 
 
 Note: All manufacturing operation must be conducted under conditions and
 controls that protect against the potential for growth of
 microorganisms and the potential for contamination. 
 
 Only plastic pallets are permitted inside manufacturing areas where
 
 raw materials and product are exposed. Wooden pallets are only
 allowed in packaging rooms when preparing shipping boxes.
 Wooden pallets are only allowed in the warehouse, hallways and
 areas where material and product are not exposed. All wooden
 pallets must be heat-treated and marked “HT”. 
 
 The personnel must be garbed appropriately with frocks and/or
 disposable lab coats, shoe covers and/or dedicated shoes as
 applicable, hair nets, beard covers, safety glasses and gloves (refer to
 SOP A-108 Good Manufacturing Practices and Personal Hygiene).
 
 Identify all processing lines and major equipment used during
 manufacturing to indicate their contents, including the name of the
 
 dietary supplement and the specific batch number. 
 
 Each stage of the manufacturing process should be approved or
 rejected by QC personnel. 
 
 6.3.2.1 Weighing and Blending Process (Refer to SOP B-901 Weighing and
 
 Blending Procedure). 
 
 6.3.2.1.1 A QC inspection of the room, equipment, balances, and
 utensil cleanliness must take place prior to any weighing
 and blending. The inspection must be documented on the
 BPR. 
 
 6.3.2.1.2 Before weighing a raw material, the following must be
 verified by the operator and QC inspector and the
 
 verification recorded in the BPR: 
 
 e Check the RMID against the BPR. 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 7 of 14 
 Composition of Solid Dosage Finished Products 
 
 Check the description of the material against the BPR.
 
 Ensure the material has been released by QC.
 
 Check the expiration date of the material. 
 
 6.3.2.1.3. During the weighing, the following steps should be observed:
 
 Tare the scale to read zero between each weighing
 step. 
 
 The R # of each raw material must be documented
 in the BPR. 
 
 Each step of the weighing process should be 
 
 checked by a second production person and/or QC
 inspector as per BPR. 
 
 6.3.2.1.4 During the blending, the following steps should be
 observed: 
 
 Place the weighed raw materials into the blender,
 
 following the instructions on the BPR. 
 
 Each step of the blending process must be 
 checked by a second production person and/or QC as
 per BPR. 
 
 After the blending process QC inspector performs
 CCP 1 Blending (Absence of Foreign Material and
 Bulk Density) to ensure blend uniformity, to
 determine that a product conforms to specifications
 and make a disposition decision (Refer to SOP C-707
 
 Critical Control Point Specifications). 
 
 If the blend is approved, QC will release the blend
 for the next manufacturing stage. 
 
 If the blend is not approved, Quality and R&D will be
 notified of the failure. 
 
 6.3.2.2 Encapsulation Process (Refer to SOP B-903 Encapsulation
 
 Procedure) 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 8 of 14 
 Composition of Solid Dosage Finished Products 
 
 6.3.2.2.1 A QC inspection of the room, equipment, balances, and
 utensil cleanliness must take place prior to any
 encapsulation. Encapsulation blend has been released by
 QC and all drums are labeled released/approved. The
 
 inspection must be documented onthe BPR. 
 
 6:3:2.2.2 Prior to encapsulation, the material ID and description,
 batch number, and material quantity must be checked
 against the BPR. Also verify that the blend has been
 released by QC for further processing (refer to SOP B-
 
 903 Encapsulation Procedure). 
 
 6.3.2.2.3 Make all necessary adjustments to be sure capsules meet
 the current product specifications, specified into BPR:
 
 e Capsule Weight 
 
 e Capsules are completely locked with consistent size,
 
 color, and powder quantity 
 
 e Make sure to use the correct capsule size, color and
 material specified into BPR. 
 
 6.3.2.2.4 QC inspector should perform CCP2 — Encapsulation
 (Encapsulation Startup Check) to determine that a
 
 product conforms to specifications and make a 
 disposition decision (Refer to SOP C-707 Critical
 Control Point Specifications). 
 
 6.3.2.2.5 During the encapsulation, the following steps should
 
 be observed: 
 
 e Every 30 minutes the operator and every hour QC
 record the in process weight on BPR 
 
 e In process containers identified with in process label
 including: 
 
 e Product Name 
 
 e Batch Number 
 
 e Container XX (Number of container) 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 9 of 14 
 Composition of Solid Dosage Finished Products 
 
 e Weight per Container 
 
 6.3.2.2.6 The encapsulation procedures stated in the BPR must be
 followed. Keep encapsulation equipment adjusted to
 maintain weight tolerances. 
 
 G.3.221 After the completion of encapsulation process, capsules
 must be released and approved by QC personnel. 
 
 6.3.2.2.8 If, during the encapsulation process, any problem with the
 encapsulation machine occurs, stop the machine and
 immediately notify the department supervisor. 
 
 6.3.2.3. Compression Process (Refer to SOP B-902 Compression Procedure)
 
 6.3.2.3.1 A QC inspection of the room, equipment, balances, and
 utensil cleanliness must take place prior to any
 compression. Compression blend has been released by
 QC and all drums are labeled released/approved. The
 
 inspection must be documented on the BPR. 
 
 6.3.2.3.2 Make all necessary adjustments to the press so that
 tablets meet the current product specifications, specified
 into BPR: 
 
 e Tablet weight 
 
 e Tablet hardness 
 
 e Friability and thickness (if required) 
 
 6.3.2.3.3 QC inspector should perform CCP2 - Tableting
 (Compression Startup Check) to determine that a
 product conforms to specifications and make a 
 
 disposition decision (Refer to SOP C-707 Critical
 Control Point Specifications). 
 
 6.3.2.3.4 During the compression, the following _ steps
 should be observed: 
 
 e Every 30 minutes the operator and every hour QC
 record the in process weight, hardness, thickness on
 
 BPR. 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 10 of 14 
 Composition of Solid Dosage Finished Products 
 
 e In process containers identified with in process label
 including: 
 
 e Product Name 
 
 e Batch Number 
 
 e Container XX (Number of container) 
 
 6.3.2.3.5 The compression procedures stated in the BPR must be
 followed. Keep compression equipment adjusted to
 maintain weight tolerances. 
 
 6.3.2.3.6 If, during the compression process, any problem with the
 
 tablet press occurs, stop the press and immediately notify
 the department supervisor. 
 
 6.3.2.3.7 After the completion of compression process, tablets
 must be released and approved by QC personnel. 
 
 Note: For coated tablets follow SOP B-703 Solid Coating
 Pan and B-704 Perforated Coating Pan and coating
 
 record(s) in the BPR. 
 
 6.3.2.4 Packaging Process (Refer to SOP B-904 Packaging Procedure)
 
 6.3.2.4.1 Prior to the beginning of the packaging process, the
 container(s) containing the tablets/capsules and all
 packaging components must be inspected by QC 
 
 personnel for the correct product, batch number, and
 packaging. They should be released and approved by QC
 personnel. This has to be documented in the BPR.
 
 6.3.2.4.2 A QC inspection of the packaging area, equipment,
 utensil and scale(s) must take place prior to the
 
 beginning of packaging process. The inspection must be
 documented on the BPR. 
 
 6.3.2.4.3 Tablets, capsules and powder products must pass through
 the metal detector without indication of containing metals
 — CCP4 Metal Detection (Tablets, CapsulesandPowders.
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 11 of 14 
 Composition of Solid Dosage Finished Products 
 
 6.3.2.4.4 The packaging procedure stated in the BPR must be
 strictly followed. 
 
 6.3.2.4.5 Packaging operator performs four bottle checks at the
 beginning and every 30 minutes until the end of the
 
 packaging process for product quality. 
 
 6.3.2.4.6 QC performs four bottle checks at the beginning and
 every one hour until the end of the packaging process for
 product quality. Interval based inspections can be
 adjusted as needed based on risk (refer to SOP B-905
 
 Quality Control Inspection Process). 
 
 e Verify fill count for tablets/capsules and fill weight
 for powders. 
 
 e For Tablets — must be free of chips, breaks, capping,
 foreign matter and discoloration. Tablets must be
 
 consistent in size, color, and shape. 
 
 e For Capsules — must be free of folding, dimpling,
 tears. Capsules must be completely locked with
 consistent size, color, visual powder quantity.
 
 e For Powder — must be free of foreign material and
 
 consistent in color 
 
 6.3.2.4.7. The labels must be issued by LC/QC and must be the
 correct labels for the job. The product label used must be
 affixed on the appropriate space(s) in the BPR before the
 beginning of the labeling process and signed by QC
 
 personnel. 
 
 6.3.2.4.8 The labeling instructions stated in the BPR must be
 strictly followed. 
 
 6.3.2.4.9 Packaging operator performs four bottle checks at the
 beginning and every 30 minutes and at the end of the
 
 labeling process for product quality. 
 
 6.3.2.4.10 A QC Inspector performs four bottle checks at the
 beginning and hour until the end of the run to ensure
 product quality. Intervals can be adjusted as needed based
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 12 of 14 
 Composition of Solid Dosage Finished Products 
 
 on risk (refer to SOP B-905 Quality Control Inspection
 Process). 
 
 6.3.2.4.11 At the completion of packaging, QC inspector should
 submit to QC Lab reserve samples and stability samples
 (if required). (Refer to SOP E-702 Finished Product
 
 Sampling Procedure). 
 
 6.3.2.4.12 The pallet(s) with packaged product/bulk should be
 properly identified with product name, customer name,
 batch number, pallet(s) number and quantity. QC will
 place a "Hold-Pending Release" tag on each pallet and
 
 product should be moved to designated area holding for
 QC test results and release by QC department (Refer to
 SOP E-802 Quarantine of Materials/ Products). 
 
 Note: All components and finished products should be
 held under appropriate conditions of temperature,
 
 humidity, and light so that the identity, purity,
 strength, and composition of the components and
 dietary supplements are not affected. 
 
 6.3.2.5 Finished Product Testing and Release 
 
 6.3.2.5.1 QC inspector takes the test samples/micro samples to
 
 the laboratory for analysis and logs them in the QC
 laboratory sample log book. 
 
 6.3.2.5.2 QC Lab is responsible for testing all finished products in
 accordance with SOP D-902 Establishment of 
 Specifications. 
 
 6.3.2.5.3. QC Lab performs the specified testing in accordance with
 applicable laboratory method standard operating
 procedures and documents in a laboratory notebook or on
 the appropriate forms (Refer to section D SOPs 
 Laboratory Operations and Specifications). 
 
 6.3.2.5.4 At the completion of testing, QC Lab enters the results of
 
 the testing on the Method Specific Test Tickets and
 Finished Product Test Ticket — Internal CofA. 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 Ensuring the Identity, Purity, Strength and A-116 7 | Page 13 of 14 
 Composition of Solid Dosage Finished Products 
 
 6.3.2.5.5 Any finished product testing failures [i.e. Out of
 Specification (OOS) results] are investigated per SOP
 D-105 Out of Specification/Out of Trend Investigation.
 
 6.3.2.5.6 QC should perform the calculations necessary to
 verify the correct addition of each ingredient to the
 
 batch and complete the IAV with the results of these
 calculations (Refer to SOP D-403 Calculations for
 Ingredient Addition Verification for Finished 
 Products). 
 
 6.3.2.5.7 Completed IAV, completed Method Specific Test 
 
 Tickets (with reference to any laboratory notebook
 containing testing performed), completed Finished
 Product Test Ticket and CofA are collected by QC and
 included in the executed BPR. 
 
 6.3.2.5.8 Quality Systems will review the entire BPR to ensure
 
 that it is complete, all required information is entered
 or attached, and all the signatures/ dates are in place
 and will make a final disposition (Refer to SOP C-103
 Batch Production Record Review and Release of 
 
 Finished Products). 
 
 e If the product is released, Quality Systems will
 notify applicable departments and a warehouse
 associate will remove the "Hold- Pending Release"
 
 tag. 
 
 e If the product is rejected, QC will change the
 "Hold- Pending Release" tag to a "QC Hold" tag
 on a pallet and move the pallet to the designated
 area until further investigation is performed and
 
 finalized. 
 
 

[SOP 

 Standard Operating Procedure SOP No | Rev 
 A-116 7 
 Ensuring the Identity, Purity, Strength and Page 14 of 14 
 Composition of Solid Dosage Finished Products 
 
 7.0 Revision History 
 
 Revision Date Description of Changes CCR # By 
 | 05/24/13 New 13-402 V. Iltcheva 
 Combined section 5.3.2.1.4 & 5.3.2.1.5, changed the SOP 
 title in section 5.2.3.1 & 5.2.3.2.1, changed "every 30 min" to
 06/18/13 13-464 V. Iltcheva 
 "every | hour" for QA check in section 5.3.2.2.4.1 & 
 5.3.2.3.4.1, added "thickness" in section 5.3.2.3.4.1 
 Updated SOP format, changed "QA" to "QC", added Product 
 Profiles in definition section and 6.3.1.1, removed section 
 5.2.2.1, added note to 6.2.3.2 for partial shipments, added note
 to 6.2.3.2.1 for C of A challenge, added note for plastic/ wooden
 07/25/14 14-0583 V. Iltcheva 
 pallets in 6.3.2, added capsules are completely locked with 
 consistent size, color, and powder quantity in section 6.3.2.2.2,
 added metal detection for powders in 6.3.2.4.3, changed QC 
 inspection from 30min to 1h 
 Biennial review: added reference to SQF. Removed obsolete 
 08/24/16 16-0778 K. Burris 
 SOP references. 
 Changed title. Aligned protocol to reflect processes for all solid
 12/07/16 16-1116 B. Johns 
 dosage form finished products manufactured at Ion Labs. 
 Update outdated definitions and references, update procedure to
 04/14/20 include the use of Batchmaster, edit language for clarity, edit to CC-20-0320 S. Sassman
 be consistent with current practices. 
 Removed reference to FPSS in definitions and SQF Code in 
 08/04/21 CC-21-0310 C. Mitchell 
 references. Removed CCP6 from section 6.3.2.4.3.