Maintaining high standards of quality is crucial to ensure regulatory compliance and, consequently, patient safety. The International Council for Harmonisation (ICH) plays a pivotal role in setting these standards, particularly through guidelines like ICH Q9, which focuses on quality risk management (QRM).
The ICH Q9 guideline, first introduced in 2005, aimed to provide a systematic approach to QRM, facilitating consistent risk-based decisions across various stages of a product's lifecycle. Over time, limitations and areas for improvement were identified, leading to a revision. In this post, we break down the core enhancements in ICH Q9(R1) and how they shape a more mature, science-driven approach to QRM.
ICH Q9(R1), which has been in effect since July 2023, addresses key areas such as:
ICH Q9(R1) emphasizes "hazard identification" over "risk identification" to better align with the risk assessment process.
Subjectivity can impact every stage of a quality risk management process, especially the identification of hazards and the estimation of the probability of occurrence and severity of harm. It can also impact the estimation of risk reduction and the effectiveness of decisions made from quality risk management activities. Subjectivity cannot be entirely eliminated, but it can be minimized by addressing bias and assumptions.
At ValGenesis, we recommend the following:
Enabling this virtuous circle allows you to make QRM decisions that are science- and knowledge-based, and thus less subjective.
Quality and manufacturing issues can lead to product shortages. ICH Q9(R1) highlights the importance of proactively identifying and implementing preventive measures that support product availability. The following factors can affect supply and product availability and should be considered when applying QRM:
Enhancements include better monitoring systems to detect and manage supply chain issues that could affect product quality and availability. This is critical for maintaining manufacturing reliability and compliance with Good Manufacturing Practice (GMP).
ICH Q9(R1) provides clearer direction on the degree of formality required in QRM activities. It aids in structuring QRM processes more effectively across different scenarios.
Quality risk management activities will have different degrees of formality depending on certain factors such as:
Higher levels of uncertainty, importance, or complexity may necessitate more formal quality risk management approaches to mitigate potential risks and facilitate effective risk-based decision-making.
| Characteristics | Lower Levels of Formality | Higher Levels of Formality |
|---|---|---|
| QRM Process | One or more parts of the process are not performed as stand-alone activities but are addressed within other elements of the quality system. | All parts are explicitly performed. |
| QRM Tools | QRM tools might not be used in some or all parts of the process. | QRM tools are used in some or all parts of the process. |
| Team Involved | A cross-functional team might not be necessary. | A cross-functional team is assembled for the QRM activity. |
| Facilitator | N/A | The use of a facilitator with experience and knowledge of the quality risk management process may be integral to a higher-formality process. |
| Reporting | Stand-alone quality risk management reports might not be generated. The outcome of the quality risk management process is usually documented in the relevant parts of the quality system. | Stand-alone quality risk management reports or related documents that address all aspects of the process may be generated and documented (e.g., within the quality system). |
Additionally, while importance and complexity are relatively straightforward to identify, uncertainty can be managed, up to a point, with a systematic approach for acquiring, analyzing, storing, and disseminating scientific information, which, in turn, will inform all QRM activities. Setting up a system to manage this knowledge effectively and ensure a more accurate assessment of proper formality is recommended.
ICH Q9(R1) includes expanded focus on making risk-based decisions that are well-informed and based on standardized approaches. This includes utilizing robust knowledge management practices to support decision-making throughout a product's lifecycle.
Risk-based decision-making is implied in all quality risk management activities. These include decisions related to:
ICH Q9(R1) predicts three approaches to risk-based decision-making:
These approaches are applied according to the level of formality required, which depends on importance, complexity, and uncertainty.
| High Importance | Low Importance | |||
|---|---|---|---|---|
| Low complexity | High complexity | Low Complexity | High Complexity | |
| Low uncertainty | Less structured | Highly structured | Less structured | Highly structured |
| High uncertainty | Highly structured | Highly structured | Highly structured | Highly structured |
To effectively comply with ICH Q9(R1), pharmaceutical companies must leverage advanced quality risk management software. Here’s why:
The ICH Q9(R1) guideline underscores the importance of robust quality risk management practices in the pharmaceutical industry.
Implementing a comprehensive quality risk management software solution is a strategic advantage. It enhances the accuracy of risk assessments, improves decision-making, and ensures compliance with current ICH Q9(R1) expectations. As the industry continues to evolve, leveraging advanced digital tools for QRM remains essential for maintaining high quality and safety standards.
Using quality risk management software to ensure ICH Q9(R1) compliance is a proactive step toward achieving excellence in pharmaceutical manufacturing. It ensures that all aspects of QRM are handled efficiently and effectively, paving the way for safer products and a more reliable supply chain.
ValGenesis iCMC™ is designed for the pharmaceutical industry to ensure compliance with regulatory guidelines such as ICH Q9(R1). It offers tools for systematic hazard identification, risk assessment, and risk-based decision-making. The application integrates data from multiple sources, automates QRM processes, and provides real-time monitoring and comprehensive documentation. Its user-friendly dashboards and seamless integration with other enterprise systems support effective risk management, enhancing overall manufacturing quality and safety.