A company can:
You must:
A product is contained in a bottle. The bottles should be inspected for suitability and contamination, including the material’s chances of contaminating the product itself (especially if plastic). Samples should be swabbed and tested. Samples from each batch should be held in storage. Batch records should be kept and each step of the process should be signed off by QA.
The cap that goes on the bottle should be similarly treated.
Any additional components should be so treated, including inserts such as cotton wool, plastic dispensers, etc.
The product going into the bottle should be manufactured in identifiable batches, with batch records. In essence, continuous production into a storage tank or sorting area is not acceptable as it intermixes product made from different raw material and from different production equipment. Each batch of product should be sampled and tested against a validated assay on calibrated instruments. Primary validation of calibration should be performed on two instruments to prove traceability on a regular basis (minimum annually). Validation should be traceable to NIST standards.
The facility producing the product must conform to a long list of requirements, including hot water in the restrooms and containment against contamination from outside the facility, including rodents, insects, etc.
The filling, closure and labeling of the product must occur under controlled conditions, with batch records and sampling, including held samples.
The final packaging and shipment of batches must be documented and QA’ed.
In short, cGMP is all embracing and doesn’t apply to “special” circumstances or products. It applies equally to OTC and prescription medicines.
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