Page 32 - Packaging Controls
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GMP Training – Packaging Controls by www.gmpsop.com


                                                    Exactly what has been done


                                                    What has been used

                                                    When the operation was performed


                                                    Who performed the operation













               Reconciliation of printed matter is one of the key GMP packaging controls. The
               reconciliations indicate how many printed matter items are not accounted far.

               It is well-known that incorrect calculations are common mistakes in this area,
               for example, assuming that any unaccounted for numbers must be rejects. While
               reconciliation limits should be tight around 100%, it isn't expected that every
               result is exactly that number.



               What do the GMP rules say?

               US FDA CFR 211


               Sec. 211.125 Labeling issuance. (extract)

               (a) Strict control shall be exercised over labeling issued for use in drug product
               labeling operations.
               (b) Labeling materials issued for a batch shall be carefully examined for identity
               and  conformity  to  the  labeling  specified  in  the  master  or  batch  production

               records.
               (c) Procedures shall be used to reconcile the quantities of labeling Issued, used,
               and returned, and shall require evaluation of discrepancies found between the
               quantity of drug product finished and the quantity of labeling Issued when such
               discrepancies  are  outside  narrow  preset  limits  based  on  historical  operating

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