Professional Documents
Culture Documents
Contents [hide]
1
History
Applications
Principles
Process
Southeast Asia
See also
References
Further reading
External links
History[edit]
Shortly after World War II, when synthetic insecticides became widely
available, entomologists in California developed the concept of "supervised
insect control".[7] Around the same time, entomologists in the US Cotton Belt
were advocating a similar approach. Under this scheme, insect control was
"supervised" by qualified entomologists and insecticide applications were
based on conclusions reached from periodic monitoring of pest and naturalenemy populations. This was viewed as an alternative to calendar-based
programs. Supervised control was based on knowledge of the ecology and
analysis of projected trends in pest and natural-enemy populations.
Supervised control formed much of the conceptual basis for the "integrated
control" that University of California entomologists articulated in the 1950s.
Integrated control sought to identify the best mix of chemical and biological
controls for a given insect pest. Chemical insecticides were to be used in the
manner least disruptive to biological control. The term "integrated" was thus
synonymous with "compatible." Chemical controls were to be applied only
after regular monitoring indicated that a pest population had reached a level
(the economic threshold) that required treatment to prevent the population
from reaching a level (the economic injury level) at which economic losses
would exceed the cost of the control measures.
IPM extended the concept of integrated control to all classes of pests and was
expanded to include all tactics. Controls such as pesticides were to be applied
as in integrated control, but these now had to be compatible with tactics for
all classes of pests. Other tactics, such as host-plant resistance and cultural
manipulations, became part of the IPM framework. IPM combined
entomologists, plant pathologists, nematologists and weed scientists.
In the United States, IPM was formulated into national policy in February 1972
when President Richard Nixon directed federal agencies to take steps to
advance the application of IPM in all relevant sectors. In 1979, President
Jimmy Carter established an interagency IPM Coordinating Committee to
ensure development and implementation of IPM practices.[8]
Applications[edit]
IPM is used in agriculture, horticulture, human habitations, preventive
conservation and general pest control, including structural pest management,
turf pest management and ornamental pest management.
Principles[edit]
An American IPM system is designed around six basic components:[9]
determines the optimal time for a specific insect outbreak. Plant pathogens
follow similar patterns of response to weather and season.
Mechanical controlsShould a pest reach an unacceptable level, mechanical
methods are the first options. They include simple hand-picking, barriers,
traps, vacuuming and tillage to disrupt breeding.
Biological controlsNatural biological processes and materials can provide
control, with acceptable environmental impact, and often at lower cost. The
main approach is to promote beneficial insects that eat or parasitize target
pests. Biological insecticides, derived from naturally occurring
microorganisms (e.g.Bt, entomopathogenic fungi and entomopathogenic
nematodes), also fall in this category. Further 'biology-based' or 'ecological'
techniques are under evaluation.
Responsible useSynthetic pesticides are used as required and often only at
specific times in a pest's life cycle. Many newer pesticides are derived from
plants or naturally occurring substances (e.g.nicotine, pyrethrum and insect
juvenile hormone analogues), but the toxophore or active component may be
altered to provide increased biological activity or stability. Applications of
pesticides must reach their intended targets. Matching the application
technique to the crop, the pest, and the pesticide is critical. The use of lowvolume spray equipment reduces overall pesticide use and labor cost.
An IPM regime can be simple or sophisticated. Historically, the main focus of
IPM programmes was on agricultural insect pests.[11] Although originally
developed for agricultural pest management, IPM programmes are now
developed to encompass diseases, weeds and other pests that interfere with
management objectives for sites such as residential and commercial
structures, lawn and turf areas, and home and community gardens.
Process[edit]
IPM is the selection and use of pest control actions that will ensure favourable
economic, ecological and social consequences[12] and is applicable to most
agricultural, public health and amenity pest management situations. The IPM
process starts with monitoring, which includes inspection and identification,
followed by the establishment of economic injury levels. The economic injury
levels set the economic threshold level. That is the point when pest damage
(and the benefits of treating the pest) exceed the cost of treatment.[13] This
can also be an action threshold level for determining an unacceptable level
that is not tied to economic injury. Action thresholds are more common in
structural pest management and economic injury levels in classic agricultural
pest management. An example of an action threshold is one fly in a hospital
operating room is not acceptable, but one fly in a pet kennel would be
acceptable. Once a threshold has been crossed by the pest population action
steps need to be taken to reduce and control the pest. Integrated pest
management employ a variety of actions including cultural controls, including
physical barriers, biological controls, including adding and conserving natural
predators and enemies to the pest, and finally chemical controls or
pesticides. Reliance on knowledge, experience, observation and integration of
multiple techniques makes IPM appropriate for organic farming (excluding
synthetic pesticides). These may or may not include materials listed on the
Organic Materials Review Institute (OMRI)[14] Although the pesticides and
particularly insecticides used in organic farming and organic gardening are
generally safer than synthetic pesticides, they are not always more safe or
environmentally friendly than synthetic pesticides and can cause harm.[15]
For conventional farms IPM can reduce human and environmental exposure to
hazardous chemicals, and potentially lower overall costs.
Once the pest is known, knowledge of its lifecycle provides the optimal
intervention points.[17] For example, weeds reproducing from last year's
seed can be prevented with mulches and pre-emergent herbicide.
Specific sites may also have varying requirements. E.g., white clover may be
acceptable on the sides of a tee box on a golf course, but unacceptable in the
fairway where it could confuse the field of play.[18]
Southeast Asia[edit]
The Green Revolution of the 1960s and '70s introduced sturdier plants that
could support the heavier grain loads resulting from intensive fertilizer use.
Pesticide imports by 11 Southeast Asian countries grew nearly sevenfold in
value between 1990 and 2010, according to FAO statistics, with disastrous
results. Rice farmers become accustomed to spraying soon after planting,
triggered by signs of the leaf folder moth, which appears early in the growing
season. It causes only superficial damage and doesn't reduce yields. In 1986,
Indonesia banned 57 pesticides and completely stopped subsidizing their use.
Progress was reversed in the 2000s, when growing production capacity,
particularly in China, reduced prices. Rice production in Asia more than
doubled. But it left farmers believing more is betterwhether it's seed,
fertilizer, or pesticides.[32]
The brown planthopper (Nilaparvata lugens), the farmers' main target, has
become increasingly resistant. Since 2008, outbreaks have devastated rice
harvests throughout Asia, but not in the Mekong Delta. Reduced spraying
allowed natural predators to neutralize planthoppers in Vietnam. In 2010 and
2011, massive planthopper outbreaks hit 400,000 hectares of Thai rice fields,
causing losses of about $64 million. The Thai government is now pushing the
"no spray in the first 40 days" approach.[32]
By contrast early spraying kills frogs, spiders, wasps and dragonflies that prey
on the later-arriving and dangerous planthopper and produced resistant
strains. Planthoppers now require pesticide doses 500 times greater than
originally. Overuse indiscriminately kills beneficial insects and decimates bird
and amphibian populations. Pesticides are suspected of harming human
health and became a common means for rural Asians to commit suicide.[32]
In 2001, scientists challenged 950 Vietnamese farmers to try IPM. In one plot,
each farmer grew rice using their usual amounts of seed and fertilizer,
applying pesticide as they chose. In a nearby plot, less seed and fertilizer
were used and no pesticides were applied for 40 days after planting. Yields
from the experimental plots was as good or better and costs were lower,
generating 8% to 10% more net income. The experiment led to the "three
reductions, three gains" campaign, claiming that cutting the use of seed,
fertilizer and pesticide would boost yield, quality and income. Posters,
leaflets, TV commercials and a 2004 radio soap opera that featured a rice
farmer who gradually accepted the changes. It didn't hurt that a 2006
planthopper outbreak hit farmers using insecticides harder than those who
didn't. Mekong Delta farmers cut insecticide spraying from five times per crop
cycle to zero to one.
The Plant Protection Center and the International Rice Research Institute
(IRRI) have been encouraging farmers to grow flowers, okra and beans on rice
paddy banks, instead of stripping vegetation, as was typical. The plants
attract bees and a tiny wasp that eats planthopper eggs, while the
vegetables diversify farm incomes.[32]
Rodenticide
From Wikipedia, the free encyclopedia
"Rat poison" redirects here. For the window manager, see ratpoison.
Some rodenticides are lethal after one exposure while others require more
than one. Rodents are disinclined to gorge on an unknown food (perhaps
reflecting an adaptation to their inability to vomit), preferring to sample, wait
and observe whether it makes them or other rats sick.[1][2] This
phenomenon of bait shyness or poison shyness is the rationale for poisons
that kill only after multiple doses.
Besides being directly toxic to the mammals that ingest them, including dogs,
cats, and humans, many rodenticides present a secondary poisoning risk to
animals that hunt or scavenge the dead corpses of rats.
Contents [hide]
1
Chemical preparations
1.1
Anticoagulants
1.2
Metal phosphides
1.3
Hypercalcemia
1.4
Other
1.5
Combinations
Alternatives
Non-target issues
3.1
3.2
See also
References
Further reading
External links
Chemical preparations[edit]
Anticoagulants[edit]
Anticoagulants are defined as chronic (death occurs one to two weeks after
ingestion of the lethal dose, rarely sooner), single-dose (second generation)
or multiple-dose (first generation) rodenticides, acting by effective blocking of
the vitamin K cycle, resulting in inability to produce essential blood-clotting
factors mainly coagulation factors II (prothrombin) and VII (proconvertin).
In addition to this specific metabolic disruption, massive toxic doses of 4hydroxycoumarin, 4-thiochromenone and indandione anticoagulants cause
damage to tiny blood vessels (capillaries), increasing their permeability,
causing diffuse internal bleeding. These effects are gradual, developing over
several days. In the final phase of the intoxication, the exhausted rodent
collapses due to hemorrhagic shock or severe anemia and dies calmly. The
question of whether the use of these rodenticides can be considered humane
has been raised.[3]
The main benefit of anticoagulants over other poisons is that the time taken
for the poison to induce death means that the rats do not associate the
damage with their feeding habits.
Metal phosphides[edit]
Before the advent of anticoagulants, phosphides were the favored kind of rat
poison. During World War II, they came into use in United States because of
shortage of strychnine due to the Japanese occupation of the territories
where the strychnine tree is grown. Phosphides are rather fast-acting rat
poisons, resulting in the rats dying usually in open areas, instead of in the
affected buildings.
Other[edit]
Civilian Public Service worker distributes rat poison for typhus control in
Gulfport, Mississippi, ca. 1945.
Other chemical poisons include:
Alternatives[edit]
More environmentally-safe preparations, such as powdered corn cob, have
been developed and were approved in the EU and patented in the US in 2013.
These preparations rely on dehydration to cause death.[11][12]
Non-target issues[edit]
Secondary poisoning and risks to wildlife[edit]
One of the potential problems when using rodenticides is that dead or
weakened rodents may be eaten by other wildlife, either predators or
scavengers. Members of the public deploying rodenticides may not be aware
of this or may not follow the product's instructions closely enough.
The faster a rodenticide acts, the more critical this problem may be. For the
fast-acting rodenticide bromethalin, for example, there is no diagnostic test
or antidote.[13]
This has led environmental researchers to conclude that low strength, long
duration rodenticides (generally first generation anticoagulants) are the best
balance between maximum effect and minimum risk.[14]
This article does not cite any sources. Please help improve this article by
adding citations to reliable sources. Unsourced material may be challenged
and removed. (March 2008) (Learn how and when to remove this template
message)
Pesticide residues on crops are monitored through the use of Maximum
Residue Limits (MRL), which are based on the analysis of the quantity of a
given chemical remaining on food product samples. The MRL is usually
determined by repeated (on the order of 10) field trials, where the crop has
been treated according to good agricultural practice (GAP) and an
appropriate pre harvest interval or withholding period has elapsed. For many
pesticides this is set at the Limit of Determination (LOD) since only major
pesticides have been evaluated and understanding of Acceptable daily intake
(ADI) is incomplete (i.e. producers or public bodies have not submitted MRL
data often because these were not required in the past). LOD can be
considered a measure of presence/absence, but certain residues may not be
quantifiable at very low levels. For this reason the limit of quantification (LOQ)
is often used instead of the LOD. As a rule of thumb the LOQ is approximately
two times the LOD. For substances that are not included in any of the
annexes in EU regulations, a default MRL of 0.01 mg/kg normally applies.
It follows that adoption of GAP at the farm level must be a priority, and
includes the withdrawal of obsolete pesticides. With increasingly sensitive
detection equipment, a certain amount of pesticide residue will often be
measured following field use. In the current regulatory environment, it would
be wise for cocoa producers to focus only on pest control agents that are
permitted for use in the EU and US. It should be stressed that MRLs are set on
the basis of observations and not on ADIs. If MRL of some drug is not known it
is calculated by the formula: MRL= ADI*W/MDI*100*(safety factor)
Ornamental Crops[edit]
In some cases in the EU MRL's are also used for ornamental produce, and
checked against MRL's for food crops. While this is a sound approach for the
general environmental impact, it doesn't reflect potential exposure of people
handling ornamentals. A swap test can eliminate this gap. MRL's for
ornamental produce can sometimes result in a conflicting outcome because
of the absence of pre harvest intervals (PHI) or withholding periods for
ornamentals, specifically in crops where harvesting is continuous, like roses.
This happens when a grower is following the label recommendations and the
produce is sampled shortly after.
------------------Occupational Safety and Health Administration
From Wikipedia, the free encyclopedia
Not to be confused with EU-OSHA, the European Agency for Safety and
1971
Jurisdiction
Headquarters
Employees
Washington, D.C.
2,265 (2015)[1]
Annual budget
Agency executive
David Michaels, Assistant Secretary
Parent department United States Department of Labor
Website
www.osha.gov
Contents [hide]
1
History
OSHA coverage
2.1
2.2
2.3
2.4
Enforcement
Recordkeeping requirements
Whistleblower protection
Compliance assistance
Controversy
10
See also
11
References
12
External links
History[edit]
OSHA officially formed on April 28, 1971, the date that the OSH Act became
effective.[3] George Guenther was appointed as the agency's first director.
OSHA has a number of training, compliance assistance, and health and safety
recognition programs throughout its history. The OSHA Training Institute,
which trains government and private sector health and safety personnel,
began in 1972.[3] In 1978, the agency began a grantmaking program, now
called the Susan Harwood Training Grant Program, to train workers and
employers in reducing workplace hazards.[3] OSHA started the Voluntary
Protection Programs in 1982, which allow employers to apply as "model
workplaces" to achieve special designation if they meet certain requirements.
[3]
OSHA coverage[edit]
The OSHA Act covers most private sector employers and their workers, in
addition to some public sector employers and workers in the 50 states and
certain territories and jurisdictions under federal authority. Those jurisdictions
include the District of Columbia, Puerto Rico, the Virgin Islands, American
Samoa, Guam, Northern Mariana Islands, Wake Island, Johnston Island, and
the Outer Continental Shelf Lands as defined in the Outer Continental Shelf
Lands Act.
State plans are OSHA-approved job safety and health programs operated by
individual states instead of federal OSHA. Federal OSHA approves and
monitors all state plans and provides as much as fifty percent of the funding
for each program. State-run safety and health programs are required to be at
least as effective as the federal OSHA program.
OSHAs protection applies to all federal agencies. Section 19 of the OSH Act
makes federal agency heads responsible for providing safe and healthful
working conditions for their workers. OSHA conducts inspections of federal
facilities in response to workers reports of hazards and under programs that
target high hazard federal workplaces.[5]
Federal agencies must have a safety and health program that meets the
same standards as private employers. OSHA issues virtual fines to federal
agencies following an inspection where violations are found, OSHA issues a
press release stating the size the fine would be if the federal agency were a
private sector employer. Under a 1998 amendment, the OSHA Act covers the
U.S. Postal Service the same as any private sector employer.
By law, employers must provide their workers with a workplace that does not
have serious hazards and must follow all OSHA safety and health standards.
Employers must find and correct safety and health problems. OSHA further
requires that employers must first try to eliminate or reduce hazards by
making feasible changes in working conditions rather than relying on
personal protective equipment such as masks, gloves, or earplugs. Switching
to safer chemicals, enclosing processes to trap harmful fumes, or using
ventilation systems to clean the air are examples of effective ways to
eliminate or reduce risks.
Barry Salerno Talks with a Homeowner in Washington, Ill. about Fall Hazards &
Unstable Surfaces
Inform workers about chemical hazards through training, labels, alarms, colorcoded systems, chemical information sheets and other methods.
Provide safety training to workers in a language and vocabulary they can
understand.[8]
Keep accurate records of work-related injuries and illnesses.
Perform tests in the workplace, such as air sampling, required by some OSHA
standards.
Provide required personal protective equipment at no cost to workers.
(Employers must pay for most types of required personal protective
equipment.)[9][10]
Provide hearing exams or other medical tests when required by OSHA
standards.
Post OSHA citations and annually post injury and illness summary data where
workers can see them.[11][12]
Notify OSHA within eight hours of a workplace fatality. Notify OSHA within 24
hours of all work-related inpatient hospitalizations, all amputations, and all
losses of an eye (1-800-321-OSHA [6742]).
Prominently display the official OSHA Job Safety and Health Its the Law
poster[13] that describes rights and responsibilities under the OSH Act.
Not retaliate or discriminate against workers[14] for using their rights under
the law, including their right to report a work-related injury or illness.
Workers have the right to:[15]
their workplace.
Receive copies of the results from tests and monitoring done to find and
measure hazards in their workplace.
Receive copies of their workplace medical records.
Participate in an OSHA inspection and speak in private with the inspector.
File a complaint with OSHA if they have been retaliated or discriminated
against by their employer as the result of requesting an inspection or using
any of their other rights under the OSH Act.
File a complaint if punished or retaliated against for acting as a
whistleblower under the 21 additional federal laws for which OSHA has
jurisdiction.[14]
Temporary workers must be treated like permanent employees. Staffing
agencies and host employers share a joint accountability over temporary
workers. Both entities are therefore bound to comply with workplace health
and safety requirements and to ensure worker safety and health. OSHA could
hold both the host and temporary employers responsible for the violation of
any condition.[17]
Employers must also comply with the General Duty Clause of the OSH Act.
This clause requires employers to keep their workplaces free of serious
recognized hazards and is generally cited when no specific OSHA standard
applies to the hazard.
In its first year of operation, OSHA was permitted to adopt regulations based
on guidelines set by certain standards organizations, such as the American
Conference of Governmental Industrial Hygienists, without going through all
of the requirements of a typical rulemaking. OSHA is granted the authority to
promulgate standards that prescribe the methods employers are legally
required to follow to protect their workers from hazards. Before OSHA can
issue a standard, it must go through a very extensive and lengthy process
that includes substantial public engagement, notice and comment. The
agency must show that a significant risk to workers exists and that there are
feasible measures employers can take to protect their workers.
2002: Exit Routes, Emergency Action Plans, and Fire Prevention Plans
Enforcement[edit]
OSHA is responsible for enforcing its standards on regulated entities.
Compliance Safety and Health Officers carry out inspections and assess fines
for regulatory violations. Inspections are planned for worksites in particularly
hazardous industries. Inspections can also be triggered by a workplace
fatality, multiple hospitalizations, worker complaints, or referrals.
OSHA is a small agency, given the size of its mission: with its state partners,
OSHA has approximately 2,400 inspectors covering more than 8 million
workplaces where 130 million workers are employed. In Fiscal Year 2012
(ending Sept. 30), OSHA and its state partners conducted more than 83,000
inspections of workplaces across the United States just a fraction of the
nations worksites.[19] According to a report by AFLCIO, it would take OSHA
129 years to inspect all workplaces under its jurisdiction.[20]
Current workers or their representatives may file a complaint and ask OSHA
to inspect their workplace if they believe that there is a serious hazard or that
their employer is not following OSHA standards. Workers and their
representatives have the right to ask for an inspection without OSHA telling
their employer who filed the complaint. It is a violation of the OSH Act for an
employer to fire, demote, transfer or in any way discriminate against a
worker for filing a complaint or using other OSHA rights.
OSHA carries out its enforcement activities through its 10 regional offices and
90 area offices.[19] OSHAs regional offices are located in Boston, New York
City, Philadelphia, Atlanta, Chicago, Dallas, Kansas City metropolitan area,
Denver, San Francisco, and Seattle.
Recordkeeping requirements[edit]
Tracking and investigating workplace injuries and illnesses play an important
role in preventing future injuries and illnesses. Under OSHAs Recordkeeping
Employers with more than ten employees and whose establishments are not
classified as a partially exempt industry must record serious work-related
injuries and illnesses using OSHA Forms 300, 300A and 301. Recordkeeping
forms, requirements and exemption information are at OSHAs website.[22]
Whistleblower protection[edit]
OSHA enforces the whistleblower provisions of the Occupational Safety and
Health Act and 21 other statutes protecting workers who report violations of
various airline, commercial motor carrier, consumer product, environmental,
financial reform, food safety, health care reform, nuclear, pipeline, public
transportation agency, maritime and securities laws.[14] Over the years,
OSHA has been responsible for enforcing these laws that protect the rights of
workers to speak up without fear of retaliation, regardless of the relationship
of these laws to occupational safety and health matters.[14]
Compliance assistance[edit]
OSHA has developed several training, compliance assistance, and health and
safety recognition programs throughout its history.
The OSHA Training Institute, which trains government and private sector
health and safety personnel, began in 1972.[23] In 1978, the agency began a
grant making program, now called the Susan Harwood Training Grant
Program, to train workers and employers in identifying and reducing
workplace hazards.[23]
OSHA also provides compliance assistance through its national and area
offices. Through hundreds of publications in a variety of languages, website
safety and health topics pages, and through compliance assistance staff
OSHA provides information to employers and workers on specific hazards and
OSHA rights and responsibilities.[26]
Controversy[edit]
Much of the debate about OSHA regulations and enforcement policies
revolves around the cost of regulations and enforcement, versus the actual
benefit in reduced worker injury, illness and death. A 1995 study of several
OSHA standards by the Office of Technology Assessment (OTA) found that
OSHA relies "generally on methods that provide a credible basis for the
determinations essential to rulemakings". Though it found that OSHA's
finding and estimates are "subject to vigorous review and challenge", it
stated that that this is natural because "interested parties and experts
involved in rulemakings have differing visions".[27]
OSHA has come under considerable criticism for the ineffectiveness of its
penalties, particularly its criminal penalties. The maximum penalty is a
misdemeanor with a maximum of 6-months in jail.[28][dubious discuss] In
response to the criticism, OSHA, in conjunction with the Department of
Justice, has pursued several high-profile criminal prosecutions for violations
under the Act, and has announced a joint enforcement initiative between
OSHA and the United States Environmental Protection Agency (EPA) which
has the ability to issue much higher fines than OSHA. Meanwhile,
Congressional Democrats, labor unions and community safety and health
advocates are attempting to revise the OSH Act to make it a felony with much
higher penalties to commit a willful violation that results in the death of a
worker. Some local prosecutors are charging company executives with
manslaughter and other felonies when criminal negligence leads to the death
of a worker[citation needed].
During its more than 40 years of existence, OSHA has secured only 12
criminal convictions.[when?][29]
OSHA has been accused of being more devoted to the numbers of inspections
than to actual safety.[citation needed] Industry associations and unions have
resorted to court action to force OSHA to promulgate new standards such as
the hexavalent chromium standard. OSHA has also been criticized for taking
decades to develop new regulations.[citation needed] Speaking about OSHA
under the George W. Bush presidency on the specific issue of combustible
dust explosions, Chemical Safety Board appointee Carolyn Merritt said:[30]
The basic disappointment has been this attitude of no new regulation. They
don't want industry to be pestered. In some instances, industry has to be
pestered in order to comply.
------------------Good manufacturing practice
From Wikipedia, the free encyclopedia
Good manufacturing practices (GMP) are the practices required in order to
Contents [hide]
1
High-level details
Guideline versions
Enforcement
See also
References
Sources
External links
High-level details[edit]
Good manufacturing practice guidelines provide guidance for manufacturing,
testing, and quality assurance in order to ensure that a food or drug product
is safe for human consumption. Many countries have legislated that food and
pharmaceutical and medical device manufacturers follow GMP procedures
and create their own GMP guidelines that correspond with their legislation.
The quality is built into the product and GMP is the most essential part of
ensuring this product quality.
Guideline versions[edit]
GMPs are enforced in the United States by the U.S. Food and Drug
Administration (FDA), under Title 21 CFR. The regulations use the phrase
"current good manufacturing practices" (cGMP) to describe these guidelines.
Courts may theoretically hold that a product is adulterated even if there is no
specific regulatory requirement that was violated as long as the process was
not performed according to industry standards.[citation needed] Since June
2010, a different set of cGMP requirements have applied to all manufacturers
of dietary supplements.[1]
GMC is part of quality assurance which ensures that products are consistently
produced and controlled to the quality standards appropriate to their
intended use and as required by marketing authorization or product
specification.
Enforcement[edit]
Within the European Union, GMP inspections are performed by National
Regulatory Agencies (e.g., GMP inspections are performed in the United
Kingdom by the Medicines and Healthcare Products Regulatory Agency
(MHRA)); in the Republic of Korea (South Korea) by the Ministry of Food and
Drug Safety (KFDA); in Australia by the Therapeutic Goods Administration
(TGA); in Bangladesh by the Directorate General of Drug Administration
(DGDA); in South Africa by the Medicines Control Council (MCC); in Brazil by
the National Health Surveillance Agency (ANVISA); in India GMP inspections
are carried out by state Food and Drugs Administrations (FDA) and these FDA
report to the Central Drugs Standard Control Organization; in Pakistan by the
Drug Regulatory Authority of Pakistan; in Nigeria by NAFDAC; and by similar
national organisations worldwide. Each of the inspectorates carry out routine
GMP inspections to ensure that drug products are produced safely and
correctly; additionally, many countries perform pre-approval inspections (PAI)
for GMP compliance prior to the approval of a new drug for marketing.
Regulatory agencies (including the FDA in the U.S. and regulatory agencies in
many European nations) are authorized to conduct unannounced inspections,
though some are scheduled. FDA routine domestic inspections are usually
unannounced, but must be conducted according to 704(a) of the FD&C Act
(21 USCS 374), which requires that they are performed at a "reasonable
time". Courts have held that any time the firm is open for business is a
reasonable time for an inspection.
To ensure that corrective and preventive actions are effective, the systematic
investigation of the root causes of failure is pivotal. CAPA is part of the overall
quality management system (QMS).
Contents [hide]
1
Concepts
See also
References
External links
Concepts[edit]
Clearly identified sources of data which identify problems that will be
investigated.
Root cause analysis to identify the cause of a discrepancy or deviation and
suggest corrective actions of a problem which is identified.
A common misconception is that the purpose of preventive action is to avert
the occurrence of a similar potential problem. This process is all part of
corrective action, because it is a process of determining such similarities that
should take place in the event of a discrepancy.
required. It can be seen that both fit into the PDCA (plan-do-check-act)
philosophy as determined by the Deming-Shewhart cycle.
Root cause is the identification of the source of the problem where the
person(s), system, process or external factor is identified as the cause of the
non conformity.
1.0
General Controls
GMPs for the Food Industry (21 CFR Part 110)? Yes ___
No ___
GMPs for the Dietary Supplements Industry (21 CFR Part 111)? Yes ___
___
GMPs for the Drug Industry (21 CFR Part 210/211)? Yes ___
No ___
GMPs for the Medical Device Industry (21 CFR Part 820)? Yes ___
GMPs for Active Pharmaceutical Ingredients (ICH Q7)? Yes ___
1.1
No
No ___
No ___
1.301 Circle the types of orientation provided to each new employee: (1)
Company brochure (2) Literature describing GMP regulations and stressing
importance of following instructions. (3) On-the-job training for each function
to be performed (before the employee is allowed to perform such tasks). (4)
Other: enter in notebook.
1.302 211.25(a) Does each employee receive retraining on an SOP
(procedures) if critical changes have been made in the procedure?
1.303 Indicate how on-going, periodic GMP training is accomplished.
1.304 211.25 is all training documented in writing that indicates the date of
the training, the type of training, and the signature of both the employee and
the trainer?
1.305 211.25 Are training records readily retrievable in a manner that
enables one to determine what training an employee has received, which
employees have been trained on a particular procedure, or have attended a
particular training program?
1.306 Are GMP trainers qualified through experience and training?
1.307 211.25(a) Are supervisory personnel instructed to prohibit any
employee who, because of any physical condition (as determined by medical
examination or supervisory observation) that may adversely affect the safety
or quality of drug products, from coming into direct contact with any drug
component or immediate containers for finished product?
1.308 211.28(d) Are employees required to report to supervisory personnel
any health or physical condition that may have an adverse effect on drug
product safety and purity?
1.309 211.25(a) Are temporary employees given the same orientation as
permanent employees?
1.310 211.34 Are consultants, who are hired to advise on any aspect of
manufacture, processing, packing or holding, of approval for release of drug
products, asked to provide evidence of their education, training, and
experience?
1.311 211.34 Are written records maintained stating the name, address,
qualifications, and date of service for any consultants and the type of service
they provide?
1.4
1.601 Does this facility have a periodic and formal review of the cost of
quality?
1.602 Does this facility have the ability, through personnel, software, and
accounting records, to identify and capture quality costs?
1.603 Does this facility make a conscious effort to reduce quality costs?
2.0
Design Control
3.0
Facility Control
3.1
3.101 211.42(a) Are all parts of the facility constructed in a way that makes
them suitable for the manufacture, testing, and holding of drug products?
3.102 211.42(b) Is there sufficient space in the facility for the type of work
and typical volume of production?
3.103 Does the layout and organization of the facility prevent contamination?
3.2
3.301 211.56(a) Is this facility free from infestation by rodents, birds, insects
and vermin?
3.302 211.56(c) Does this facility have written procedures for the safe use of
suitable, (e.g. those that are properly registered) rodenticides, insecticides,
fungicides, and fumigating agents?
3.303 Is this facility maintained in a clean and sanitary condition?
3.304 Does this facility have written procedures that describe in sufficient
detail the cleaning schedule, methods, equipment and material?
3.305 Does this facility have written procedures for the safe and correct use
of cleaning and sanitizing agents?
3.306 211.58 Are all parts of the facility maintained in a good state of
repair?
3.307 211.52 Is sewage, trash and other refuse disposed of in a safe and
sanitary manner (and with sufficient frequency?)
3.4
Equipment Control
4.1
4.2
Equipment Identification
4.201 211.105 Are all pieces of equipment clearly identified with easily
visible markings?
4.202 211.105(b) Are all pieces of equipment also marked with an
identification number that corresponds with an entry in an equipment log?
4.203 Does each piece of equipment have written instructions for
maintenance that includes a schedule for maintenance?
4.204 Is the maintenance log for each piece of equipment kept on or near the
equipment?
4.3
4.301 211.67(b) Are written procedures established for the cleaning and
maintenance of equipment and utensils?
4.302 Are these procedures followed?
4.303 211.67(b)(1) Does a written procedure assign responsibility for the
cleaning and maintenance of equipment?
4.304 211.67(b)(2) Has a written schedule been established and is it
followed for the maintenance and cleaning of equipment?
4.305 Has the cleaning procedure been properly validated?
4.306 211.67(b)(2) If appropriate, is the equipment sanitized using a
procedure written for this task?
4.307 211.67(b)(3) Has a sufficiently detailed cleaning and maintenance
procedure been written for each different piece of equipment to identify any
necessary disassembly and reassembly required to provide cleaning and
maintenance?
4.308 211.67(b)(3) Does the procedure specify the removal or obliteration of
production batch information from each piece of equipment during its
cleaning?
4.309 Is equipment cleaned promptly after use?
4.310 Is clean equipment clearly identified as "clean" with a cleaning date
shown on the equipment?
4.311 211.67(b)(5) Is clean equipment adequately protected against
contamination prior to use?
4.401 211.68(a) Does the facility have approved written procedures for
checking and calibration of each piece of measurement equipment? (Verify
procedure and log for each piece of equipment and note exceptions in
notebook with cross reference.)
4.402 211.68(a) Are records of calibration checks and inspections
maintained in a readily retrievable manner?
4.5
Material/Component Control
5.1
5.209 211.84(c)(5) Containers from which samples have been taken are so
marked indicating date and approximate amount taken.
5.210 Each sample container is clearly identified by material or component
name, lot number, date sample taken, name of person taking sample, and
original container identification.
5.211 211.84(d)(1)(2) At least one test is conducted to confirm the identity
of a raw material (bulk chemical or pharmaceutical) when a Certificate of
Analysis is provided by supplier and accepted by QA.
5.212 If a Certificate of Analysis is not accepted for a lot of material, then
additional testing is conducted by a written protocol to determine suitability
for purpose.
5.213 211.84(d)(6) Microbiological testing is conducted where appropriate.
5.3
(Verify that materials and components are stored and handled in a way
that prevents contamination, mixups, and errors.)
5.301 211.42(b) Are incoming material and components quarantined until
approved for use?
5.302 Are all materials handled in such a way to prevent contamination?
5.303 Are all materials stored off the floor?
5.304 Are materials spaced to allow for cleaning and inspection?
5.305 211.122(d) Are labels for different products, strengths, dosage forms,
etc., stored separately with suitable identification?
5.306 Is label storage area limited to authorized personnel?
5.307 211.89 Are rejected components, material, and containers
quarantined and clearly marked to prevent their use?
5.4
Operational Control
6.1
6.110 211.125(a) Does a written procedure specify how labels are issued,
used, reconciled with production, returned when unused, and the specific
steps for evaluation of any discrepancies?
6.111 211.125(d) Do written procedures call for destruction of excess
labeling on which lot or control numbers have been stamped or imprinted?
6.2
identity, strength, quality, purity and are they approved or rejected by Quality
Control?
6.403 211.160(b) Are there laboratory controls including sampling and
testing procedures to assure conformance of components, containers,
closures, in-process materials, and finished product specifications?
6.5
Reprocessing/Disposition of Materials
7.1
7.101 211.30 Do written procedures indicate how and who verifies that
correct containers and packages are used for finished product during the
finishing operation?
7.102 211.134(a) In addition, do written procedures require that
representative sample of units be visually examined upon completion of
packaging to verify correct labeling?
7.103 211.137(a) Are expiration dates stamped or imprinted on labels?
Distribution Controls
Marketing Controls
7.401 The current regulation does not address marketing controls per se