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Audits of Investigational Medicinal Product Manufacturers and Manufacturers of APIs for Clinical Trials

Since 31 JAN 2022, the Detailed Commission guidelines on GMP for Investigational Medicinal Products for human use, pursuant to the second subparagraph of Article 63(1) of Regulation (EU) No 536/2014 is applicable for human investigational medicinal products (IMPs). Other parts of EU GMP part I still apply if the above guideline refers to it (e.g., chapter 1, chapter 2 or chapter 6). In addition, Annex 1 is applicable for sterile IMPs.
Compared to commercial medicinal products, the manufacturing of investigational medicinal products (IMPs) has certain particularities and additional requirements, for instance there are many manual process steps and there’s less routine. There are different study designs with verum, placebo and comparator products, the handling of randomization codes, blinding processes, the handling of returns, etc. and up to now not fully validated production processes. Our auditors have experience and are trained to take into account the special requirements for IMPs. Our audit approach is highly customized and takes into account our clients’ specific requirements, for instance the review of certain deviations, changes, complaints or studies.
The production of APIs for use in clinical trials is described in EU GMP part II and specifically in chapter 19 of EU GMP part II. Here, the particularities of the manufacture of new APIs for investigational clinical use are described. For instance, batch sizes are much smaller and therefore small- to pilot-scale equipment is used. Normally only single batches are produced with many changes from batch to batch and higher variations in yield. Full process validation usually starts only in phase III and is completed before commercial use. blue inspection has experience with this special type of API production and we would be happy to support you in qualification of your API supplier.

If required, audits of IMP or API for clinical trial manufacturers may be accompanied by your technical expert.
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