E-702

Finished Product Sampling Procedure

Section E — Materials Management Revision 9 12 pages

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1.0 Purpose 
 
 The purpose of this procedure is to define the process of selecting and executing a finished
 product sampling plan. This procedure provides guidance for selecting the samples for identity,
 
 purity, strength, and composition testing. 
 
 2.0 Scope 
 
 This procedure applies to all products that have been manufactured and/or packaged by Ion
 
 Labs, Inc. 
 
 3.0 Responsibility 
 
 3.1 It is the responsibility of QC Laboratory Management to implement and maintain this
 
 procedure. 
 
 3.2 It is the responsibility of QC personnel to strictly follow the procedure.
 
 3.3. ‘It is the responsibility of the QC Laboratory to test samples that have been submitted,
 using in-house testing or outside testing if required. 
 
 3.4 It is the responsibility of QC Laboratory Management to define any deviations from the
 default reserve and stability reserve sampling procedures. 
 
 4.0 Definitions 
 
 4.1 Finished Product — Final Dosage form of any Dietary supplement, OTC drug product,
 
 pet product, or cosmetic 
 
 4.2 MBR — Master Batch Record 
 
 
 

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 Finished Product Sampling Procedure 
 4.3 DC — Document Control 
 
 4.4 BPR — Batch Production Record 
 
 5.0 References 
 
 5.1 D-201-F1, Form, QC Laboratory Sample Log Book 
 
 5.2 E-702-F1, Form, Master Sampling Plan 
 
 a3 E-702-F2, Form, Special Sampling Request 
 
 5.4 E-702-F3, Form, Confirmation of Sample Collection 
 
 5.5 C-502, SOP, Record Storage, Retention, and Destruction 
 
 5.6 21 CFR Part 111.83 
 
 5.7 21 CFR Part 211.170 
 
 6.0 Sampling for Identity, Strength, and Composition Testing 
 
 6.1 The sampling requirements outlined in this procedure apply to all products
 manufactured at Ion Labs and can only be superseded if the Product Profile details an
 
 alternative sampling and testing plan that is supported by scientific justification.
 
 6.2 Collect laboratory samples for all finished product release testing, with the exception of
 
 microbial analysis (reference section 7.0), from the final finished product dosage form,
 i.e. processing step just prior to packaging. Alternatively, conduct testing on a
 
 composite sample of beginning, middle, and end of packaging. 
 
 6.3 As samples are collected, complete form E-702-F3 Confirmation of Sample Collection.
 An entry is to be made and signed for at each collection time point.
 
 
 

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 Finished Product Sampling Procedure 
 6.4 Each BPR will contain form E-702-F1 Master Sampling Plan, which outlines the
 required samples for each stage of manufacturing. These sampling plans are product
 
 specific and will be built at time of MBR creation. 
 
 6.5 Tablets and Capsules 
 
 6.5.1 For each day and shift of manufacturing, tablets and capsules will be sampled
 throughout the compression/encapsulation process and composited into an
 
 HDPE bottle with closure. Sampling can occur at any point in each shift.
 
 6.5.2 Collection bottles will be labeled to contain the following information:
 
 6.5.2.1 Product name 
 
 6.5.2.2. Batch number 
 
 6.5.2.3 Initials of QC and date 
 
 Note: If multiple tablet or encapsulation machines are running the same batch
 
 number simultaneously, combine samples from each room into the
 
 same bottle so a composite sample is made from all rooms.
 
 6.6 Bulk Powder 
 
 6.6.1 Bulk powder finished product samples will be collected from the beginning,
 
 middle, and end of packaging, i.e. bottles, canisters, or stick packs. Laboratory
 
 testing will be completed by compositing these samples. 
 
 6.6.2 Collection bottle(s) will be labeled to contain the following information:
 
 6.6.2.1 Product name 
 
 6.6.2.2. Batch number 
 
 6.6.2.3 Initials of QC and date 
 
 6.7 — Liquids 
 
 
 

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 6.74 Mix tank lab samples will be taken from the top and bottom of the tank, upon
 completion of mixing the liquid batch. Approximately 100ml of product from
 
 the top and 100ml of the product from the bottom of the Tank will be collected
 using a clean sterile 100ml green cap cup. The bottles will be identified as CCP
 
 6 samples with following information: 
 
 6.7.1.1 Product Name 
 
 6.7.1.2 Batch Number 
 
 6.7.1.3 Circle if sample is from the Top or Bottom of the Mixing Tank
 
 6.7.1.4 Initials and date sample was taken 
 
 6.7.2 Liquid laboratory finished product release testing will be sampled from the
 liquid blend tank into an appropriate container(s). 
 
6.7.3 Collection bottle(s) will be labeled to contain the following information:

 6.7.3.1 Product name 
 
 6.7.3.2 Batch number 
 
 6.7.3.3 Initials of QC and date 
 
 6.8 Chewable Gels (Gummies) 
 
 Chewable Gel finished product samples will be collected from the beginning,
6.8.1 middle, and end of packaging. Laboratory testing will be completed by

 compositing these samples. 
 
 Packaged containers will be labeled to contain the following information:
6.8.2 6.8.2.1 Product name

 6.8.2.2 Batch number 
 
 
 

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 6.8.2.3 Initials of QC and date 
 
 7.0 Sampling for Purity Testing (Microbial Testing) 
 
 7.1 For all products, laboratory samples intended for microbial analysis will be taken from
 beginning, middle, and end of packaging. These samples will then be composited in the
 
 laboratory and evaluated for microbial contamination. 
 
 7.2 For products packaged as bulk, microbial analysis will be performed on the final dosage
 form as a composite of beginning, middle, and end of manufacturing process.
 
 7.3 The bottle will be identified as micro sample with the following information:
 
 7.3.1. Product name 
 
 7.3.2 Sampling timeframe (beginning, middle, or end) 
 
 7.3.3. Batch number 
 
 7.3.4 Initials of QC and date 
 
 8.0 Reserve and Stability Reserve Sampling 
 
 Sampling points — sampling will be staggered between the beginning, middle, and end
8.1 of the process.

 8.1.1 For bottled and blistered products, samples will be taken during the final
 
 packaging process. For bulk packaged products, samples will be taken during
 the bulk packaging operation. The default reserve quantity for any product is six
 
 bottles, two beginning, two middle and two end samples. 
 
 8.1.2 Reserve samples will be held in the same container/closure in which the
 
 packaged and labeled product is distributed. 
 
 8.1.3 Reserve samples will be taken in the following manner: 
 
 

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 8.1.3.1 Bottling — six reserve samples will be pulled during the bottling
 
 process. If bottles will be further packaged into secondary or tertiary
 
 packaging, reserve samples must be packaged and submitted to the lab
 in same manner. 
 
 8.1.3.2 Blister packaging — six reserve samples will be pulled during the final
 pack out of blisters (ex. Cartoning process). 
 
 8.1.3.3 Bulk packaging (capsules/tablets) — a minimum of 60 capsules/tablets
 
 will be placed in six 200cc HDPE containers with closures.
 
 8.1.3.4 Bulk packaging (powders) — during the filling of the containers, six
 
 reserve samples will be pulled. 
 
 81.4 The bottles will be identified as reserve samples with the following information:
 
 8.1.4.1 Product name 
 
 8.1.4.2 Batch number 
 
 8.1.4.3 Initials of QC and date 
 
 Deviation from the default reserve sampling procedure: 
8.1.5 81.5.1 The default number of six reserve samples can be reduced to a number
 
 no less than three bottles when sufficient dosage exists in a reserve
 
 sample to justify a reduced number of packages. The reserve quantity
 must meet the requirements of 21 CFR 111.83 and CFR 211.170.
 
 8.2 Stability Reserve Quantities 
 
 The default stability reserve quantity for any product is nine bottles/cartons,
8.2.1 three beginning, three middle and three end samples.

 Stability reserves will be held in the same container/closure assembly in which
8.2.2 the packaged and labeled dietary supplement is distributed.

 
 

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 Finished Product Sampling Procedure 
 8.2.3 The bottles/cartons will be identified as stability samples with the following
 information listed on the bottle: 
 
 8.2.3.1 Product name 
 
 8.2.3.2 Batch number 
 
 8.2.3.3 Initials of QC and date 
 
 8.2.4 Deviation from the default stability reserve sampling procedure:
 
 8.2.4.1 Stability reserves must consist of at least twice the quantity necessary
 to complete all tests or examinations to determine whether or not
 
 product meets specifications across the entire stability test cycle.
 
 8242 The default number of nine bottles/cartons can be reduced to a number
 
 no less than one bottle per stability test interval. 
 
 Example 1: 2kg powder with 2 year stability; Test intervals at 3 months, 6
 
 months, 9 months, 12 months, 18 months, and 24 months for a
 
 two year best by date: a minimum of four stability samples are
 required. 
 
 Example 2: 180ct bottle, 1 gram dosage with 3 year stability; test intervals at
 3 months, 6 months, 9 months, 12 months, 18 months, 24
 
 months, 30 months, and 36 months for a three year best by date:
 A minimum of six stability samples are required. 
 
 82.5 Justification for reduced stability reserves will be listed in the exemption section
 
 of the product profile. 
 
 8.2.6 Formulations can be bracketed or matrixed for stability testing.
 
 
 

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 Finished Product Sampling Procedure E-702 9 ERE 
 
 8.2.6.1 The bracketing or matrixing program must be defined in the exemption
 
 section of each product profile contributing to the specific bracketing
 
 or matrixing program. 
 
 8.2.6.2 Bracketed or matrixed batch reserves will be accounted for by QC
 
 chemists to determine the required number of reserve samples needed
 to meet stability objectives. 
 
 9.0 Special Sample Requests 
 
 9.1 Any requests for product samples outside of the scope of this procedure will be
 conducted using form E-702-F2 Special Sample Request. 
 
 9.1.1 Special sample requests must be completed and submitted to DC prior to batch
 
 record completion. 
 
 9.1.2 Special Sample Request forms will be included with the Master Sampling Plan
 
 located in the batch record. 
 
 9.1.3 Details on special sample request form include: 
 
 9.1.3.1 Sample Type Requested 
 
 9.1.3.2 Number of dosage/ bottles requested 
 
 9.1.3.3 Requested by and date 
 
 9.1.3.4 Collected by and date 
 
 9.1.4 Once collected, all special sample request containers will be submitted to the
 
 requestor. 
 
 10.0 Sample Logging Procedure 
 
 10.1 QC will submit the samples to the QC Laboratory and log them on form D-201-F1 QC
 
 Laboratory Sample Log Book. 
 
 
 

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 11.0 Documentation 
 
 11.1 Forms associated with this procedure will be filed in the applicable BPR and
 
 maintained as outlined in SOP C-502 Record Storage, Retention, and Destruction..
 
 12.0 Revision History 

| Rev | Date | Description of Changes | CCR # | By |
|-----|----------|------------------------|-------|----|
| 6 | 09/01/16 | Biennial review — widen scope to OTC, cosmetics, pet product : 11/29/16 Updated for liquid process sampling, added cartons, clarified 16-1092 E. Hasanbasic blistering process sampling | 16-0786 | E. Hasanbasic |
| 8 | 05/05/21 | S 1. c h A e d d d u e l d e d f r o e r v m i e E w - : 7 0 c 2 o - m F p 1 l . e te procedure rewrite. Added attachment CC- a 21- 0175 K. Burri ; s | - | - |
| 9 | 12/20/22 | Clarified finished product testing. Added Chewable gels to scope. CC- | 22-0474 | J. Sassman |

 
 

[SOP 

 IAN LABS Master Sampling Plan 
 
 Form: E-702-F1 CCR No. CC-22-0474 Revision: 1 
 
 Product Name Customer Name 
 Batch Number Product SKU 
 
 Sample Type* Sample Quantity Collection Stage 
 
 * All collected samples will be labeled as outlined above and delivered to appropriate location.
 
 Comments: 
 
 

[SOP 

 12 Special Sampling Request 
 IDN LABS Form: E-702-F2 CCRNo. — CC-22-0474 Revision: 0 
 
 Product Name 
 Batch Number 
 
 Sample Request Purpose 
 
 Sample Type Requested (Select One) umber Doce Rotiles Requested By/Date Collected By/ Date
 
 L] Powder Blend L] Inner Capsule 
 
 C] Outer Capsule [| Uncoated Tablet 
 
 L] Coated Tablet [] Liquid Blend 
 
 L] Packaged Product LJ Other: 
 L] Powder Blend L] Inner Capsule 
 
 L} Outer Capsule [_] Uncoated Tablet 
 
 [1 Coated Tablet [] Liquid Blend 
 
 CI Packaged Product L] Other: 
 
 L] Powder Blend [] Inner Capsule 
 
 [| Outer Capsule L] Uncoated Tablet 
 
 L] Coated Tablet [1 Liquid Blend 
 
 L] Packaged Product [} Other: 
 
 [| Powder Blend LJ] Inner Capsule 
 L] Outer Capsule [_] Uncoated Tablet 
 
 L_] Coated Tablet L] Liquid Blend 
 
 L] Packaged Product L] Other: 
 
 Comments: 
 
 
 Page 1 of 1 

[SOP 

 JAN LABS Form: —E-702-F3 CCoCnfRi rNmoa.t ion ofC CS-a2m2p-l0e4 C7o4l lection Revision: 0
 
 Product Name Customer Name 
 
 Batch Number Product SKU 
 
 Sample Type* Date/ Shift Collected Collection Stage** Collection Room Collected By/Date
 
 * For example, composite or microbial **For example, capsule, coated tablet, blend drop, packaging (B, M, E)
 
 Comments: