From Parts 1 and 2 of this post we highlighted that there is no formal need for an Engineering Manager or Department in GMP. In the manufacture of medicines the equipment used and the environment it is located in has a massive impact on product quality. The role of the Engineering Manager is therefore critical. In a number of engineering related GMP courses that I have presented in the past we have looked at what the delegates think the Head of Engineering’s role should be, bearing in mind the role is not defined in EU GMP. Some of the roles already assigned in GMP to the Head of Production can be delegated to them, with additional roles added as well. Their findings are below:
The Engineering Manager (suggested duties from previous delegates)
- Maintenance of premises and equipment.
- Design of facilities.
- Validation and qualification of equipment and facilities.
- Management of the calibration programme.
- Management of the Planned Preventative Maintenance programme.
- Control and operation of site services (including water, steam and HVAC systems).
- Control of engineering spares/ equipment spares.
- Control of engineering contactors.
- Approval of engineering related procedures, documents and drawings.
- Control and storage of engineering records.
- Control of equipment manuals.
- Pest control.
- Site security and access.
- Project Management.
These are roles commonly performed by Engineering departments. They are opinions from former GMP training course delegates, and should not be seen as a specific GMP requirement. Please let us know what you think. Are these similar to your own Engineering department?
Annex 1 has finally arrived, 25th Aug 2022 saw the publication of Annex 1. Normally, updates to GMP chapters and Annexes have a 6-month lead time for implementation. In the case of the new Annex 1, the lead time is 12 months, except for clause 8.123 relating to lyophilization which has 24 months lead time.
Annex 1 was first issued in 1971 as the only annex in the first ever UK guide to Good Manufacturing Practice. Since then, there have been several updates but not full revisions. In 2012 there was a proposal to revise Annex 1 with a re-proposal in 2014 by the UK’s MHRA. At the time, a full rewrite was considered unlikely and instead the intention was to provide a document that would confirm regulatory expectation and as such, not place any new requirements or costs on the pharmaceutical industry.
While this principle, is still upheld, it was clear from the first draft for public comment of December 2017, that a rewrite was being undertaken. The first draft created around 6200 comments coming from regulatory organizations, such as the pharmaceutical cooperation scheme, regulatory bodies outside of the EU, support organizations such as the Parenteral Drug Association, the Parenteral and Healthcare Sciences Society, the Pharmaceutical Microbiology Interest group as well as representatives from the manufacturers within the pharmaceutical industry to name just a few. Rarely do updates require a second public consultation but in the case of the annex 1 update a second draft was issued in March 2020 although this was a more targeted review in terms of the sections and clauses that comment was being sought for.
About the author
Andy Martin
Andy started working in the Pharmaceutical industry in 1985 as a lab technician for Smith & Nephew. Following this he had a number of roles culminating when he took over as QA Microbiology Manager. In 2003 he moved into Pharmaceutical Training and then in 2007 he moved back into Microbiology when he took up the position of Microbiology Manager for Catalent Pharma Solutions. Since 2012 he has operated as a consultant specialising in Microbiology and Quality Systems.
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Having performed this role at a major UK manufacturing site (aseptic, terminally sterilised, liquid, dry, human & vet products), I would add that a major contribution is in project management, both in terms of the facility and the equipment used.
Major facility expansion projects were generally run by a central project group (almost exclusively engineers), with a significant input from the site engineers. Upgrades, improvements and capital equipment purchase were almost always managed locally, with one of the engineering managers (site services or operational) taking the lead.
Of course, there were many other areas to which the role can contribute – efficiency improvements, lead time and stock reduction, etc. – especially where the incumbent has manufacturing experience from outside the pharmaceutical industry.
Bob Hayes, Vice-Chair, Pharmaceutical Technical Activities Committee, IMechE.
Good point Bob – post updated. Thanks for your comments.