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               Many  mis-formulation  incidents  commence  with  the  wrong  issue  of  starting
               materials or other chemicals from the store.

               The GMP rules clearly state that each issue of starting materials from the store
               must be accompanied by requisition paperwork and that there is a cross-check
               that issues match the documented request before being issued.


               The reason for this requirement is that material issue is the first point of control
               inside the factory. It is much better to prevent incorrect chemicals being issued
               in the first place rather than finding them (or not) later on. Mis-formulation can
               cause patient medication to be unsafe, which can result in serious injury or even
               death of patients.

               What do the GMP rules say?


               US FDA CFR211

               Subpart B—Organization and Personnel
               Sec. 211.22 Responsibilities of quality control unit. (extract)

               (a) There shall be a quality control unit that shall have the responsibility and
               authority to approve or reject all components, drug product containers, closures,

               in-process materials, packaging material, labeling, and drug products, and the
               authority to review production records to assure that no errors have occurred or,
               if errors have occurred, that they have been fully investigated, The quality control
               unit shall be responsible for approving or rejecting drug products manufactured,
               processed, packed, or held under contract by another company.



               International GMPs

               Chapter 4 Documentation
               Procedures and records

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