QMS - of A Company
QMS - of A Company
QMS - of A Company
STEPS DATE
Development of draft harmonized technical 1st August 2012 to 19th July 2013
documents for Good Manufacturing Practices
(GMP) for the East African Community
Medicines Regulatory Harmonization Initiative
Draft harmonized technical documents 2nd to 3rd September 2013
approved by the Steering Committee
Release of draft harmonized technical 16th September 2013 to
documents for Public Consultation 29th October 2013
End of National Consultation 28th February 2014
(deadline for comments)
Incorporation of national stakeholders inputs 13th to 17th January 2014
by EAC Secretariat in collaboration with EAC
Partner States
Release of revised technical documents for 20th January 2014
regional and international consultation
End of regional and international consultation 28th February 2014
(deadline for comments)
Draft technical documents reviewed and 12th March 2014
adopted by EAC Technical Working Group on
Medicines and Food Safety
Draft technical documents adopted by the 14th March 2014
18th EAC Sectoral Committee on Health
Draft technical documents finalized by 1st to 4th April 2014
EAC Secretariat in collaboration with
EAC Partner States
Final technical documents approved by the 17th April 2014
9th EAC Sectoral Council on Health
Date for coming into effect 17th April 2014
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FOREWORD
This Compendium has been developed to The EAC Secretariat also recognizes
provide guidance to EAC Partners States the important contribution of the Clinton
National Medicines Regulatory Authorities Health Access Initiative (CHAI) in the
to implement Quality Management System conceptualization of the African Medicines
(QMS). Regulatory Harmonization (AMRH) Initiative.
I would like to thank members of the
The Compendium was compiled by the East Technical Working Group (EWG) on Quality
African Community (EAC) Technical Working Management System (QMS) and the WHO
Group (EWG) on QMS. The EWG relied on expert who contributed to the successful
available International Standards (ISO 9000 development of the first edition of these
series, ISO/IEC 17020 and ISO/IEC 17025), Quality Management System documents.
WHO guidelines, and other experiences from
other medicine regulatory authorities. I also wish to thank the staff of EAC
Secretariat for their dedicated work and
EAC Secretariat is highly indebted to African coordination of the implementation of the
Medicines Regulatory Harmonization EAC Medicines Regulatory Harmonization
(AMRH) program partners, Bill and Melinda (MRH) Project.
Gates Foundation (BMGF), the World Bank
and the United Kingdom Department for I also acknowledge the oversight role of the
International Development (DFID) for their EAC Partner States Ministries responsible
financial assistance; and African Union New for Health, Ministries responsible for EAC
Partnership for Africa’s Development (AU- affairs and the EAC MRH Project Steering
NEPAD) for high level advocacy. Committee.
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PREFACE
2. The EAC Guidelines for the The EAC Guidelines for the implementation
implementation of Quality of Quality Management System
Management System Requirements has been developed to enable
Requirements for the Regulation uniform implementation of the EAC Quality
of Medicines, Cosmetics, Medical Management System (QMS) requirements by
Devices and Diagnostics, 2014 the EAC Partner States NMRAs.
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staff of EAC Partner States NMRAs through Special thanks go to the Bill and Melinda
disclosure of any circumstances that could Gates Foundation (BMGF), the World Bank,
give rise to a potential conflict of interest the New Partnership for Africa’s Development
related to their work. (NEPAD) for providing financial support.
The EAC QMS documents will be periodically I am grateful to the staff of EAC Secretariat,
reviewed to ensure their continued the EAC MRH project Steering Committee
consistency with any changes in the and EAC Partner States for their effective
applicable standards. coordination and implementation of this EAC
MRH project.
I would like to thank members of the
Technical Working Group (EWG) on Quality I also acknowledge the valuable contribution
Management System (QMS) for Regulations of the national and regional EAC stakeholders
of Medicines, Cosmetics , Medical who reviewed these EAC QMS documents
Devices and Diagnostics under the East and provided useful inputs.
African Community Medicines Regulatory
Harmonization (EAC-MRH) Project who
contributed to the successful development of
the first edition of these Quality Management
System (QMS) documents that include the
EAC Quality Management Requirements, the
EAC Guidelines for implementation of the
QMS requirements, the EAC Model Quality
Manual and the mandatory QMS procedures.
I would also like to thank the World Health
Organization (WHO) for providing technical
assistance towards the development of the
QMS documents.
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The EAC Sectoral Council of Ministers of Health approves the use of these QMS documents in
the East African Community Partner States’ National Medicines Regulatory Authorities (NMRAs) in
accordance with Chapter 21, Article 118 (c, d,e and f) of the EAC Treaty. Implementation of these
documents will facilitate mutual recognition of regulatory decisions and attestation of the quality
and safety medicines, cosmetics, medical devices and diagnostics manufactured, produced,
imported, exported or traded in East African Community.
The EAC partner states Ministries responsible for Health shall be responsible for the
implementation of these QMS documents by their respective NMRAs.
SIGNED by the Hon. Ministers and Leaders of Delegation this 20th day of September, 2014.
Amb. Amina Dr. Abdallah O. Hon. Léontine Hon. Valentine Hon. Shem
C. Mohamed, Kigoda Nzeyimana Rugwabiza Bageine, MP
CBS, CAV
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TABLE OF CONTENTS
0. INTRODUCTION 2
0.1. Background 2
0.2. Objectives 2
0.3. Scope of EAC QMS requirements document 2
2. Normative references 3
5. Management responsibilities 6
5.1. Management commitment 6
5.2. Customer focus 6
5.3. Quality policy 7
5.4. Planning 7
5.4.1. Quality objectives 7
5.4.2. Quality management system planning 7
5.5 Responsibility, authority and communication 7
5.5.1 Responsibility and authority 7
5.5.2 Management representative 7
5.5.3 Internal communication 8
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7. Service realizations 11
7.1 Planning of service realization 11
7.2 Customer-related processes 11
7.2.1. Determination of requirements related to the service 11
7.2.3. Review of requirements related to the service 11
7.2.3. Customer communication 12
7.2.4. Complaints and appeals 12
7.2.5. Complaints and appeals process 12
7.3. Design and development 13
7.3.1. Design and development planning 13
7.3.2. Design and development inputs 13
7.3.3. Design and development outputs 13
7.3.4. Design and development review 14
7.3.5. Design and development verification 14
7.3.6. Design and development validation 14
7.3.7.Control of design and development changes 14
7.4 Purchasing 14
7.4.1 Purchasing process 14
7.4.2 Purchasing information 14
7.4.3 Verification of purchased product 15
7.5. Service provision 15
7.5.1 Control of service provision 15
7.5.2 Validation of processes for service provision 15
7.5.3 Identification and traceability 16
7.5.4 Customer property 16
7.5.5 Preservation of product 16
7.6 Control of monitoring and measuring equipment 16
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0. INTRODUCTION 22
0.1. Background 22
0.2. Objectives 22
0.3. Scope of EAC Guidelines for implementing QMS requirements 22
1. General 23
1.1. Scope 23
2. Normative references 23
5. Management responsibility 29
5.1 Management commitment 30
5.2 Customer focus 30
5.3 Quality policy 31
5.4 Planning 31
5.4.1 Quality objectives 31
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BIBLIOGRAPHY 57
REVISION HISTORY 57
0. INTRODUCTION 59
0.1 Background 59
0.2. Objectives 59
0.3. Scope of EAC QMS model manual
1. SCOPE 60
1.1. General 60
1.2. Application of the Quality Management System 60
1.3. Exclusions from the EAC QMS requirements 60
2. NORMATIVE REFERENCES 60
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5. Management responsibilities 62
5.1 Management commitment 62
5.2 Customer focus 62
5.3 Quality policy 63
5.4 Planning 63
5.4.1 Quality objectives 63
5.4.2 Quality management system planning 63
5.5 Responsibility, authority and communication 63
5.5.1 Responsibility and authority 63
5.5.2 Management representative 63
5.5.3 Internal communication 64
5.6 Management review 64
5.6.1 General 64
5.6.2 Review input 64
5.6.3 Review output 65
6. Resource management 65
6.1 Provision of resources 65
6.2 Human resources 65
6.2.1 General 65
6.2.2 Competence, training and awareness 65
6.2.3 Impartiality and independence 65
6.2.4 Confidentiality 66
6.3 Infrastructure 66
6.4 Work environment 66
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7.4 Purchasing 68
7.4.1 Purchasing process 68
7.4.2 Purchasing information 68
7.4.3 Verification of purchased product 68
7.5 Production and service provision 69
7.5.1 Control of production and service provision 69
7.5.2 Validation of processes for production and service provision 69
7.5.3 Identification and traceability 69
7.5.4 Customer property 69
7.5.5 Preservation of the product 69
7.6. Control of monitoring and measuring equipment 70
REVISION HISTORY 74
Annex 1- Model Process interaction diagram: 75
Annex 2: Model Quality Policy. 77
Annex 3 Medicine Regulations mapping processes 78
0. INTRODUCTION 87
EAC Model Procedure for Control of Documents 87
EAC Model Procedure for Control of Records 102
EAC Model procedure for Conducting Internal Quality Audit, 107
EAC Model procedure for Control of Non-Conforming Product 118
Doc. # EAC/TF-MED/QMS/FD/SOP 118
EAC Model procedure for Handling Customer Complaints and Appeals 123
EAC Model procedure for handling Corrective and Preventive Action 128
Model standard operating procedure: 134
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PART FIVE: Code of Conduct for EAC Partner States NMRA 137
0. INTRODUCTION 138
0.1 Background 138
0.2. Objectives 138
0.4. Legal basis 138
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PART ONE
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This document outlines the quality system c) facilitate mutual recognition and
requirements for our NMRA QMS. It is confidence amongst EAC NMRAs.
intended that each NMRA uses the document
as the basis for developing and implementing 0.3. Scope of EAC QMS
its own QMS and for preparing its own quality requirements document
manual. In addition to providing a basis for
self-assessment and a reference document for This document specifies QMS requirements
use by external assessors, establishing and for EAC NMRAs in the regulation of
maintaining an effective QMS will generate medicines, cosmetics, medical devices and
confidence within and between EAC NMRAs diagnostics.
in the assessment of QMS compliance.
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These processes shall be managed by the The NMRA shall establish and maintain a
NMRA in accordance with the requirements of quality manual that includes:
this EAC QMS Requirements.
a) the scope of the quality
Where an NMRA chooses to outsource any management system the
process that affects product conformity to documented procedures
requirements, the NMRA shall ensure control established for the quality
over such processes. The type and extent management system,
of control to be applied to these outsourced or reference to them,
processes shall be defined within the quality
management system. b) a description of the interaction
between the processes of the
4.2. Documentation requirements quality management system
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Top management shall ensure that appropriate f) changes that could affect the quality
communication processes are established management system, and
within the NMRA and that communication
takes place regarding the effectiveness of the g) recommendations for improvement.
quality management system.
5.6.3. Review output
5.6. Management review
The output from the management review shall
5.6.1. General include any decisions and actions related to:
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6.2.1 General
6.2.3. Impartiality and independence
Personnel performing work affecting
conformity to product requirements shall a) The NMRA shall be responsible for
be competent on the basis of appropriate the impartiality of its activities and
education, training, skills and experience. shall not allow commercial, financial
or other pressures to compromise
NOTE: impartiality.
Conformity to service requirements can be
affected directly or indirectly by personnel b) The NMRA shall identify risks to
performing any task within the quality its impartiality on an ongoing basis.
management system. This shall include those risks
that arise from its activities, or from
6.2.2. Competence, training its relationships, or from the
and awareness relationships of its personnel.
However, such relationships do not
The NMRA shall: necessarily present an NMRA with a
risk to impartiality.
a) determine the necessary
competence for personnel c) If a risk to impartiality is identified,
performing work affecting conformity the NMRA shall be able to
to product requirements, demonstrate how it eliminates or
minimizes such risk.
b) where applicable, provide training
or take other actions to achieve the d) The NMR shall have top
necessary competence, management commitment to
impartiality.
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a) The NMRA shall be responsible, The NMRA shall determine, provide and
through legally enforceable maintain the infrastructure needed to
commitments, for the management achieve conformity to product requirements.
of all information obtained or Infrastructure includes, as applicable,
created during the performance
of its regulatory activities. The a) buildings, workspace and
NMRA shall inform the client, in associated utilities,
advance, of the information
it intends to place in the public b) process equipment (both hardware
domain. Except for information and software), and
that the client makes publicly
available, or when agreed c) supporting services (such as
between the NMRA and the transport, communication or
client (e.g. for the purpose information systems).
of responding to complaints), all
other information is considered 6.4. Work environment
proprietary information and shall be
regarded as confidential. The NMRA shall determine and manage
the work environment needed to achieve
NOTE: conformity to product requirements.
Legally enforceable commitments can be, for
example, contractual agreements. NOTE:
The term “work environment” relates to those
b) When the NMRA is required by law conditions under which work is performed
or authorized by contractual including physical, environmental and other
commitments to release confidential factors (such as noise, temperature, humidity,
information, the client or individual lighting or weather).
concerned shall, unless prohibited
by law, be notified of the information
provided.
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Where service requirements are changed, the 7.2.5. Complaints and appeals process
NMRA shall ensure the relevant documents
are amended and that relevant personnel are 7.2.4.6 The handling process for complaints
made aware of the changed requirements. and appeals shall include at least
the following elements and
7.2.3. Customer communication methods:
The NMRA shall determine and implement a) a description of the process for
effective arrangements for communicating with receiving,
customers in relation to:
b) validating,
a) service information,
c) investigating the complaint or
b) enquiries, new service information appeal, and deciding what actions
including amendments, and are to be taken in response to it;
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7.2.4.10 Whenever possible, the NMRA 7.3.2. Design and development inputs
shall give formal notice of the end of
the complaint and appeals handling Inputs relating to service requirements shall
process to the complainant be determined and records maintained (see
or appellant. 4.2.4).
The NMRA shall plan and control the design b) applicable statutory and regulatory
and development of service. requirements,
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The NMRA shall ensure the adequacy of 7.5.2 Validation of processes for
specified purchase requirements prior to their service provision
communication to the supplier.
The NMRA shall validate any processes for
7.4.3 Verification of purchased product service provision where the resulting output
cannot be verified by subsequent monitoring
The NMRA shall establish and implement or measurement and, as a consequence,
the inspection or other activities necessary deficiencies become apparent only after the
for ensuring that purchased product meets the service has been delivered.
specified purchase requirements.
Validation shall demonstrate the ability of
Where the NMRA or its customer intends to these processes to achieve planned results.
perform verification at the supplier’s premises, The NMRA shall establish arrangements for
the organization shall state the intended these processes including, as applicable,
verification arrangements and method of
product release in the purchasing information
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The audit criteria, scope, frequency and 8.2.4. Monitoring and measurement
methods shall be defined. The selection of of service
auditors and conduct of audits shall ensure
objectivity and impartiality of the audit process. The NMRA shall monitor and measure the
Auditors shall not audit their own work. characteristics of the service to verify that
service requirements have been met. This
A documented procedure shall be established shall be carried out at appropriate stages of
to define the responsibilities and requirements the service realization process in accordance
for planning and conducting audits, with the planned arrangements (see 7.1).
establishing records and reporting results. Evidence of conformity with the acceptance
Records of the audits and their results shall criteria shall be maintained.
be maintained.
Records shall indicate the person(s)
The management responsible for the area authorizing release of product for delivery to
being audited shall ensure that any necessary the customer (see 4.2.4).
corrections and corrective actions are taken
without undue delay to eliminate detected The release of product and delivery of service
nonconformities and their causes. to the customer shall not proceed until the
planned arrangements (see 7.1) have been
Follow-up activities shall include the satisfactorily completed, unless otherwise
verification of the actions taken and the approved by a relevant authority and, where
reporting of verification results. applicable, by the customer.
The NMRA shall apply suitable methods The NMRA shall ensure that product, including
for monitoring and, where applicable, regulated product, which does not conform
measurement of the quality management to product requirements is identified and
system processes. These methods shall controlled to prevent its unintended use or
demonstrate the ability of the processes to delivery. A documented procedure shall be
achieve planned results. established to define the controls and related
responsibilities and authorities for dealing with
When planned results are not achieved, nonconforming product.
correction and corrective action shall be taken,
as appropriate. Where applicable, the organization shall deal
with nonconforming product by one or more of
NOTE: the following ways:
When determining suitable methods, it is
advisable that the NMRA consider the type a) by taking action to eliminate the
and extent of monitoring or measurement detected nonconformity;
appropriate to each of its processes in relation
to their impact on the conformity to product
requirements and on the effectiveness of the
quality management system.
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The NMRA shall determine, collect and Corrective actions shall be appropriate to the
analyse appropriate data to demonstrate the effects of the nonconformities encountered.
suitability and effectiveness of the quality A documented procedure shall be established
management system and to evaluate where to define requirements for
continual improvement of the effectiveness of
the quality management system can be made. a) reviewing nonconformities (including
customer complaints),
This shall include data generated as a result of
monitoring and measurement and from other b) determining the causes of
relevant sources. nonconformities,
The analysis of data shall provide information c) evaluating the need for action to
relating to: ensure that nonconformities do not
recur,
a) customer satisfaction (see 8.2.1),
d) determining and implementing
b) conformity to product requirements action needed,
(see 8.2.4),
e) records of the results of action taken
(see 4.2.4), and
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REVISION HISTORY
0 This is the
first edition.
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PART TWO:
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All NMRAs in the EAC have management The specific objectives of this document
systems for creating and delivering their are to:
services to customers. However, some of the
NMRAs lack quality management systems a) enable the establishment,
which would lead to wasteful processes, poor implementation and maintenance
services delivery and dissatisfied customers. of a QMS in all EAC Partner States
A quality management system significantly NMRAs in accordance with the EAC
increase the efficiency and effectiveness of QMS requirements;
the NMRA and hence, improving processes
and services delivery. b) Facilitate EAC Partner States
NMRAs to develop their quality
An efficient NMRA can be characterized by: manuals in accordance with EAC
QMS requirements
a) explicit awareness of, and concern
for, the needs of customers and 0.3. Scope of EAC Guidelines
other stakeholders (e.g. consumers, for implementing QMS
suppliers, society, staff); requirements
b) senior and middle managers who This document guides EAC Partner States
understand and focus on business NMRAs in the implementation of EAC QMS
needs; requirements.
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processes of the NMRA (e.g. After initial verification that the quality
market authorization or medicine management system is capable of meeting
registration certificates, licences, customer and regulatory requirements and
permits, good manufacturing ensuring availability of safe, quality and
practice certificates, good efficacious Medicines, the NMRAs can
distribution practice certificates, maintain the effectiveness of its established
medicine/drug register) quality management system through a range
of activities, such as:
d) “Top management” person or
group of people who directs and a) internal quality audits,
controls an NMRA at the highest
level. b) management review, and
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1
Adopted from International Organization for Standardization, Geneva 2008
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2
Adopted from Uganda National Drug Authority, Kampala 2010
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• where and when the policies are guideline, protocols and policies;
applicable within the organization. customer supplied documents etc.).
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Good recording practices require the following: NMRAs are required by EAC QMS
requirements to define the lifetime of each
a) enter data and observations as they of regulatory services. In making such a
occur, definition, the rationale should be given, but
need not be “technical’ in nature; e.g., the
b) do not pre-date or postdate records, service lifetime could have a financial or legal
basis.
c) do not use another person’s initial,
signature or equivalent, The NMRA should be responsible, through
legally enforceable commitments, for the
d) complete all fields or check-offs management of all information obtained or
when using a form, created during the performance of inspection
activities. The NMRA should inform the client,
e) refer to raw data when transferring in advance, of the information it intends to
data, and have the transcription place in the public domain.
checked by a second person,
Except for information that the client makes
f) check all entries for completeness publicly available, or when agreed between
and correctness, and the inspection body and the client (e.g. for
the purpose of responding to complaints), all
g) number the pages to ensure other information is considered proprietary
completeness. information and should be regarded as
confidential.
If an error is made or detected on a record,
it should be corrected in such a manner that NOTE:
the original entry remains legible and the Legally enforceable commitments can be, for
correction is initialled and dated. example, contractual agreements.
If appropriate, the reason for the correction When the NMRA is required by law or
should be recorded. A system should be in authorized by contractual commitments to
place which assures the integrity of electronic release confidential information, the client or
records and protects against unauthorized individual concerned should, unless prohibited
entries. by law, be notified of the information provided.
Information about the client obtained
Record retention period should take into from sources other than the client (e.g.
consideration: complainant, regulators) should be treated
as confidential.
a) lifetime of the regulatory service as
defined by the NMRAs, 5.0 Management responsibility
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In order to demonstrate that the NMRAs are In order to put the NMRAs’ quality policy and
committed to implementing its quality policy, it the strategic plan .into effect, top management
will need to identify clear, overall quality goals needs to establish clearly defined quality
for the business which are directly relevant to objectives which the NMRAs can aim for.in
the NMRAs and its customers. setting objectives and any associated targets,
timeframes for achieving the targets are
Top management’s commitment to the usually established.
quality policy should be visible, active and
effectively communicated. For example, a Quality objectives should be specific,
publicly displayed copy of the quality policy measurable, attainable, realistic and time-
signed by top management is one method bound (SMART)and related to outcomes, and
which may be used to show that commitment should be aimed at Directorates/Departments/
to both employees and customers. Another Units within the NMRAs typically establish
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5.4.2 Quality management system planning a) the quality manual and supporting
documentation
This clause deals with planning in two areas
of activity: b) results of gap analysis
This planning can assist the NMRAs to fulfil 5.5.1 Responsibility and authority
its quality objectives. Since quality objectives
can, and indeed should, change over time, this This requirement is usually achieved by
planning is likely to be ongoing, and can assist means of documented position descriptions
the quality management system to continue to which include responsibilities and authorities
be effective during and after changes. charts which describe the interrelation of
personnel. As this documentation forms part
Inputs into quality management system of the quality management system it has to
planning may include: be controlled (see 4.2.3). Responsibilities
and authorities (including those for
a) quality policy; substitute personnel) can also be included in
documented procedures. NMRAs can “map”
b) quality objectives; quality management system processes to
show the linkages between processes and the
c) regulatory requirements; responsibilities associated with activities to
be performed.
d) quality management system
standards; and
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Job descriptions and the organizational should be no conflict of interest between the
structure are reviewed and approved responsibilities for the other functions and
periodically by top management for adequacy. those relating to the quality management
system. The management representative
These documents are available throughout the may, in turn, delegate responsibilities for
company to help employees understand their the quality management system to others
responsibilities and authorities. in the NMRA. However, only one member
of management may be designated by the
A responsibility matrix in accordance with NMRA top management as its management
each applicable clause in the EAC QMS representative.
requirements, showing process owner and
process implementers for the established 5.5.3 Internal communication
directorates, departments and units within the
NMRA should be developed and annexed to For a quality management system to
the Quality Manual of the NMRA. work effectively, effective communication
is essential. Top management needs to
5.5.2 Management Representative establish the processes which encourage
people within the NMRAs to communicate
The NMRA top management should appoint a at all levels, without a ‘shoot the messenger
member of organizational management as a carrying bad news’ syndrome. To be effective,
Management Representative (Head of Quality communication processes should provide the
Management Department) with responsibility ability to:
and authority to manage the QMS. He/
she reports directly to the Chief Executive a) transmit and receive information
Officer of the NMRA to enable quick decision quickly and act on it,
making and access/authorization of resources
needed by the QMS. The MR should perform b) build mutual trust,
the functions as required by EAC QMS
requirements. c) identify examples of effective
methods and approaches within the
The Management Representative should quality management system, and
coordinate all appointed QMS officers in
their functional departments for the effective d) identify opportunities for
implementation of QMS. The Directorates or improvement.
departmental QMS officers should functionally
report to the Head of Quality Management Quality management system related
Department. information should be clear and
understandable and adapted to the personnel
The functions of the Management meant to use it. Such information relates to
Representative (MR) may be totally related top management’s expectations regarding the
to quality management system activities or quality management system performance and
may be in conjunction with other functions information related to quality management
and responsibilities within the NMRA. If the system implementation and effectiveness
MR has other functions to perform, there (for example, results of internal quality audits
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[see 8.2.2], management reviews [see The method of carrying out the review should
5.6], external assessments, and regulatory suit the NMRAs’ business practices and could
inspections). consist of:
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determined by the processes involved. quality audit (clause 8.2.2) are all likely to
Consideration needs to be given by the identify areas which could indicate a need
NMRAs’ management to the identification for improving the competence of personnel
and provision of adequate resources needed and the means for such improvement, be it
to implement its quality policy and to achieve replacement of personnel, further education
its objectives, as well as to satisfy customer or training.
requirements inclusive of applicable regulatory
requirements. All regulatory activities require competence
before they can be performed properly or
Resources can be people, infrastructure, safely (e.g. medicines evaluation, GMP
work environment, information, and financial inspection, internal quality auditing). It may
resources. Responsibility for provision of be necessary for people to be qualified or
resources resides with the NMRAs regardless formally certified for some activities.
of whether associated processes are Education and training provided for full time,
performed by the NMRAs itself or outsourced. part-time, and contract personnel, should be
tailored to the person’s assignment.
Types of resources - financial, human,
physical and technological resources Such training and education should cover:
Personnel performing work affecting c) the quality policy and other internal
conformity to product requirements should policies,
be competent on the basis of appropriate
education, training, skills and experience. d) the role of the employee, and
Conformity to service requirements can be
affected directly or indirectly by personnel e) the procedures and instructions of
performing any task within the quality relevance to them.
management system.
Training may be carried out in stages, and
6.2.2 Competence, awareness usually includes follow-up or refresher
and training training, induction training, specific on job
training, follow-up training and refresher
The NMRAs needs to regularly review the training as needed and planned. Persons and
experience, qualifications, capabilities and functions who are assigned responsibility via
abilities of personnel, especially in those areas the documented procedures of the quality
which can affect the safety and effectiveness management system, should receive training
of the regulated services. on those procedures.
Work allocation and assignment of personnel NMRAs should evaluate the effectiveness
(clause 6.2.1), management review (clause of training or other actions taken in order to
5.6), corrective action (clause 8.5.2), ensure competency. Evaluation can consist
preventive action (clause 8.5.3) and internal of polling the trained employee to assess
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whether he or she feels they have learned g) should establish a mechanism for
the required information, evaluating the work declaration and regular update
performance of the trained individual, and of personal interest. This interest
reviewing the trainer assessment of training should periodically be reviewed to
effectiveness. identify potential conflict of interest.
NMRAs should maintain records which show h) The NMRA should ensure
what competencies an employee possesses. declaration of interest by staff
Records are also kept of the training an and external experts with a
employee has received and any results of clearly defined scope. This may
that training. There cords which show that be in form of completion of
the training course has been successfully declaration form before engaging in
completed and that competence has been business dealing with the regulated
achieved can be as simple or complex as products.
necessary. At their simplest, the records
may consist of ‘sign-off’ to confirm that i) The NMRA should identify areas of
personnel can now use certain equipment, potential risks of impartially e.g.
carry out specific processes or follow certain where NMRA staff are performing
procedures. The records should include a regulatory functions with an external
clear statement that a person is now deemed party and establish mechanisms to
to be competent to do the task for which they mitigate them
were trained. The effectiveness of any further
education and training should be re-evaluated j) The NMRA should identify areas of
after a period, to ensure competence achieved interest to be declared by staff and
and continued competence of the staff. external experts’ namely financial
interests, work related to the
Training should be carried out by personnel regulated industry including
with appropriate skills, qualifications and pharmaceutical, food, cosmetic
experience. Records are typically kept to industry and links to any other
document the qualifications of the personnel industry related to the areas
used as trainers. The level of documentation regulated.
required for processes is usually determined
by the level of competence required for the 6.2.4 Confidentiality
personnel intended to perform that process.
a) The NMRA should identify areas
6.2.3 Impartiality and independence that require confidentiality and
review them on periodic basis e.g.
f) The NMRA Top management should personal data, client and customer
establish core values that include confidential information like patient
impartiality, independence and data, drug master file. .This should
equity, and proactively communicate not unnecessarily impede public
and ensure all staff understand right of access to information.
them.
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Records of the results of the review and Each directorate, department or unit of the
actions arising from the review should NMRA should consider each other within
be maintained (clause 4.2.4). Where the the same NMRA to be customers. In this
customer provides no documented statement case internal complaints can be treated
of requirement, the customer requirements as customer complaints and processed
should be confirmed by the organization accordingly. If non-conforming service
before acceptance. is involved, this should also be handled
according to the requirements of clause 8.3 of
7.2.3 Customer communication the “EAC QMS Requirements, 2014”.
The NMRA should determine and implement In evaluating the complaints and appeals, it
effective arrangements for communicating with should be considered whether:
customers in relation to:
a) the service fails to conform to its
a) Service information. This can be in specification, or
form of guidelines, circulars,
forms etc. to the stakeholders, b) conforms to its specifications but
importers, manufacturers and the nevertheless causes problems in
general public, use (such a complaint may be
caused by design fault).
b) enquiries, new service information
including amendments, and The NMRAs should formally designate a
person(s) (by role or position) to collect and
c) customer feedback, including coordinate all written and oral customer
customer complaints complaints and appeals about regulatory
services. Such person(s) should directly report
Good communication between the NMRAs to the Head of NMRA.
and the customer is essential to identify,
mitigate and resolve any misunderstandings,
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c) creating records and statistical k) the reply (if any) to the complainant
summaries to enable the major or appellant.
causes of complaints and appeals
to be determined, 7.2.5 Complaints and appeals process
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The NMRA should plan and control the design a) functional and performance
and development of regulatory services. requirements which include
During the design and development planning, registration and inspection
the NMRA should clearly define: requirements; timely delivery and
quality of service,
a) the stages of design and
development of regulatory b) applicable statutory and regulatory
services by analysing the current requirements namely the drug
situation, conceptualizing key issues laws, new regulations on
of the service, defining the registration and inspections for the
objectives and parameter within regulated products,
which the new service should be
designed; brainstorm ideas and
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Participants in such reviews should include The review of design and development
representatives of functions concerned with changes should include evaluation of the
the design and development stage(s) being effect of the changes on constituent parts and
reviewed. Records of the results of the regulatory services already delivered. Records
reviews and any necessary actions should be of the results of the review of changes and
maintained. any necessary actions should be
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Purchasing documents and records may need This check may be accomplished by various
to be identified and retained for traceability approaches, such as qualification of suppliers,
purposes to the extent required by the certificates of conformance, skip lot testing,
NMRA. This means that when evaluating the 100 % or sampling inspection, as determined
traceability requirements, consideration should by the requirements of the NMRAs’ quality
be given to what purchasing information management system.
and records may also need to be retained
to facilitate traceability. For example, if it The NMRAs’ procedures should specify
was important to know to what specification the method of verifying that consignments
revision a purchased services was ordered, received are in accordance with specifications,
then this information should be kept as part of are complete, have proper identity and
the purchasing documents or records. are undamaged. The procedures should
also include provisions for verifying that
7.4.2 Purchase Information incoming service is accompanied by the
required supporting documentation (e.g.
The NMRA should ensure the adequacy of certificates of conformity, acceptance test
specified purchase requirements prior to reports, etc.). Appropriate action in the event
communication to the supplier per process of nonconformities should be specified (see
defined in procedure procurement document. clause 8.3) so that they can be dealt with
Purchase information communicated to in a consistent manner and without undue
the suppliers contains the appropriate delay, including identification, segregation and
data needed to clearly and fully describe documentation
requirements for purchased materials
and services including suppliers profiles Analysis of previous receiving inspection
requirements, approval or qualification of data, in-house rejection history or customer
product as well as QMS requirements. complaints will influence the NMRA’s decisions
regarding the amount of inspection required,
7.4.3 Verification of purchased product and the need to reassess a supplier.
Verification of purchased service does
The NMRA has an overall responsibility for not imply that incoming service has to
ensuring the quality of purchased products. be inspected and tested by the NMRAs.
Inspection of purchased product for conformity Incoming inspection may not be required if
of purchase specification is important for the the necessary confidence in the service can
NMRAs to ensure that the purchased product be obtained by other defined processes or
fulfils specified requirements for quality. If the procedures, particularly if the information
purchased service is claimed to conform to given by a supplier is considered sufficient.
the supplier’s specification, the NMRAs should The NMRAs’ procedures should define who
check that the service meets the agreed is authorized to allow incoming service to
specification. be used before conformance to specified
requirements for quality is demonstrated.
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Such a procedure ensures that the decision The NMRA should plan and carry out service
is being taken at a level in the NMRAs which provision under controlled conditions.
is aware of the possible impact on service
realization if the incoming services do not Controlled conditions should include,
subsequently meet the requirements.
a) the availability of information that
The NMRAs’ procedures should also define describes the characteristics of the
how such service will be positively identified service,
and controlled in the event that subsequent
inspection finds nonconformities, in order to b) the availability of work instructions,
facilitate corrective action. These requirements as necessary,
apply to all services received from outside the
NMRAs’ quality management system, whether c) the use of suitable equipment,
payment occurs or not.
d) the availability and use of monitoring
Outsourced services should be subjected to and measuring equipment,
the same procedure as described above.
Ensuring control over outsourced processes e) the implementation of monitoring
does not absolve the organization of the and measurement, and
responsibility of conformityto all customers,
statutory and regulatory requirements. f) the implementation of service
delivery and post-delivery activities.
The type and extent of control to be applied to
the outsourcedprocess can be influenced by 7.5.2 Validation of processes for
factors such as: production and service provision
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Examples of such property are: The NMRA should preserve the product
during internal processing and delivery to
a) samples e.g. drug samples taken for the intended destination in order to maintain
QC testing purposes, confiscated conformity to requirements. As applicable,
drugs and market authorization preservation should include identification,
product samples, handling, packaging, storage and protection.
Preservation should also apply to the
b) dossiers and applications forms, constituent parts of a product.
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In addition, the NMRA should assess and Where appropriate, measurement equipment
record the validity of the previous measuring having a significant influence on the results
results when the equipment is found not to of the inspection should be calibrated
conform to requirements. The NMRA should before being put into service, and thereafter
take appropriate action on the equipment and calibrated according to an established
any product affected. programme.
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The EAC NMRAs top management should a) customer and user surveys,
define, plan and implement procedures:
b) feedback on aspects of service,
a) to measure, monitor and analyse
work processes and products, c) customer complaints ,
and functioning of the QMS (e.g., to
measure effectiveness in meeting d) customer requirements and contract
customer requirements); information,
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In addition to the periodic internal quality Internal audits can be partially or fully
audits, a special internal quality audit may be subcontracted.
initiated for the following purposes:
The results of audits are usually stated in
a) when evaluating the quality a written report (see clause 4.2.4) which
management system initially; indicates the deficiencies found. Avoiding
undue delay is usually accomplished by
b) when verifying that the quality including appropriate target dates for
management system continues responding to audit findings. The audit results
to meet specified requirements and have to be communicated, and should be
is being implemented; used as an input to management reviews (see
clause 5.6.2).
c) when undergoing significant
changes in functional areas, for 8.2.3 Monitoring and measurement of
example, revising procedures; processes
Planning for internal quality audits should be When determining suitable methods, it is
flexible in order to permit changes in emphasis advisable that the NMRA consider the type
based on findings and objective evidence and extent of monitoring or measurement
obtained during the audit. appropriate to each of its processes in relation
to their impact on the conformity to service
Relevant input from the area to be audited, requirements and on the effectiveness of the
as well as from other interested parties such quality management system.
as customers, corporate audit plans, or
third-party assessment NMRAs, should be The NMRA should develop procedures for
considered in the development of internal monitoring and measuring of the processes
audit plans. All NMRA functional areas as well services provided to the customer.
including the QMS directorate or department
(however named) should be audited. Each step of the implementation process
should be measured based on the different
A series of limited, well-defined audits can levels of results in the monitoring and
be as effective as one single comprehensive evaluation framework. Mechanisms to be
audit. Such an audit system can be operated adopted monitoring and measurement of
flexibly to give special, or repeat, attention to processes include; peer review, second
any areas of weakness or of other concern. assessment.
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The extent of preventive action taken should ISO/IEC 17020: 2012 Conformity assessment
be dependent upon and related to the risk, - Requirements for the operation of various
size and nature of the problem and its effect(s) types of bodies performing inspection.
on service quality. Sources for information for
initiating preventive actions include: ISO/IEC 17025: 2005 - General requirements
for the competence of testing and calibration
a) evidence that previous decisions laboratories
affecting service conformity were
false, ISO/TC 210. Medical devices - Quality
management systems - Guidance on the
b) services requiring rework, application of ISO 13485:2003, AAMI (for
ANSI).
c) in-process problems, wastage
levels, PI 002_3: 2007 PIC/S- Recommendations
on Quality system requirements for
d) final inspection failures, pharmaceutical inspectorates.
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requirements (the NMRA should profile its Top management has defined and
customers and their requirements). communicated responsibilities and authorities
throughout the NMRA.
5.3 Quality policy
The current organizational structure that
The NMRA has developed a quality policy clearly shows the inter-relationship and
(NMRA should state the quality policy reporting mechanism of the personnel in the
number) which outlines its commitment to NMRA is annexed (The NMRA should annex
implementation of QMS in the entire NMRA the current organizational structure).
and ensuring customer satisfaction.
The top management of NMRA has approved
The quality policy has been formulated current job descriptions for all members
to guide the NMRA in the fulfilment of its of staff in which the responsibilities and
mission with regard to quality and customer authorities of each of the employee positions
satisfaction (Refer to EAC Model Quality on the organizational chart are defined (Refer
Policy doc.# EAC/TF-MED/QMS/FD/POL/ to NMRA job descriptions).
N1R0).
5.5.2 Management representative
5.4 Planning
The top management of NMRA has appointed
5.4.1 Quality objectives the Head of Quality Management (HQM)
(management representative) who reports
The NMRA has developed quality objectives directly to the Chief Executive Office of
(NMRA should state the quality objectives the NMRA. The HQM has the overall
document number) including those needed responsibility and mandate on matters
to meet requirements for product and has related to QMS in all NMRA sites and with
aligned with strategic objectives of NMRA. The responsibility and authority to:
quality objectives are reviewed annually for
continuing suitability. a) ensure that the requirements of the
EAC QMS Requirements are
5.4.2 Quality management system implemented and maintained,
planning
b) resolve all matters pertaining to
The NMRA has developed a strategic plan quality,
(refer to the NMRA strategic plan) to give
directions to the achievement of the mission c) report to top management on the
and implementation of QMS. performance of the Quality
Management System and any
5.5 Responsibility, authority and need for improvement, and
communication
d) liaise with certification and
5.5.1 Responsibility and authority accreditation bodies on matters
relating to the Quality Management
System.
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conduct and professional bodies (indicate Physical parameters like lighting, temperature
document title and the year). Each employee and noise are controlled. Employees are also
has signed legally enforceable commitments motivated through several reward systems.
necessary for impartiality and objectivity.
7.0 Product realization
(Refer to EAC Model Guidelines for
Declaration of Conflict of Interest, doc.# EAC/ 7.1 Planning of product realization
TF-MED/QMS/FD/GDL/N2R0).
The NMRA has:
6.2.4 Confidentiality
a) established quality objectives,
The members of the Board, advisory
committees and staff of the NMRA have b) determined product characteristics
signed legally enforceable commitments, and processes,
which are in line with national public service
code of conduct and professional bodies c) acquired inspection and test
(indicate document title and the year) for the equipment, fixtures, appropriate
management of all information obtained or storage and transportation facilities,
created during the performance of their duties.
d) The established support
(Refer to EAC Model Oath of Secrecy doc.# departments,
EAC/TF-MED/QMS/FD/FOM/N1R0).
e) established quality assurance
6.3 Infrastructure measures at different stages of
service provision (for example,
The NMRA has provided adequate offices at first and second assessors for the
the headquarters, regional offices and ports of product evaluation of dossiers, peer
entry into the country. These offices have been review of assessment reports and
provided with the necessary utilities, process peer review of GMP reports),and
equipment (both hardware and software),
and supporting services (such as transport,
communication or information systems). f) established applicable standards,
regulatory requirements and forms
The infrastructure is continually maintained to to be used for the service provision.
achieve conformity to product requirements
7.2 Customer related processes
6.4 Work environment
7.2.1 Determination of requirements
The NMRA has provided adequate and related to the product
conducive work environment in all its offices
needed to achieve conformity to product
requirements. Requirements specified by the customer
have been determined through consultative
meetings with customers (e.g. manufactures,
importers, exporters, wholesalers and
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The print and electronic media, customer All NMRA processes have been re-engineered
care desk and stakeholders meetings are and rationalized by using management review
also used. Communication with the above results, customer feedback reports. Design
customers is also through: suggestion boxes, inputs have been identified for each process.
customer satisfaction surveys and complaint
handling system. 7.3.3. Design and Development Outputs
7.2.4 Complaints and appeals Design outputs have been identified for each
process. Information on materials, equipment,
The NMRA has established a documented competencies of personnel, process steps,
procedure (state the document number) forms and templates of reports, checklists and
for investigation and handling of market mode of services delivery to ensure conformity
complaints and appeals from customer. of the product have been developed.
(Refer to EAC Model procedure for Handling
Customer Complaints and Appeals doc.# 7.3.4 Design and Development Review
EAC/TF-MED/QMS/FD/SOP/N5R0).
Departmental team reviews, top management
review, stakeholder consultations, and Board
approval of the designs and development of
processes are carried out according to plan.
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(Refer to EAC Model procedure for ii. Quarterly, semi-annual and annual
Conducting Internal Quality Audit, doc.# EAC/ performance review meetings,
TF-MED/QMS/FD/SOP/N3R0).
iii. Internal audits,
The results of the audits are recorded
and submitted to the personnel having iv. Customer feedback,
responsibility in the area audited. The audit
is complete when the implementation and v. Annual management review
effectiveness of corrective actions has been meetings,
verified and recorded. Audit results become
part of the quality records and are presented vi. Annual self-assessment using the
at management review. WHO Assessment tool (WHO \
Data Collection Tool for the Review
8.2.3 Monitoring and measurement of Drug Regulatory Systems)
of processes
vii. Mid-term review of the NMRA
NMRA has established the monitoring and processes.
measurement process to be applied to the
realization processes necessary to achieve b) Sectoral Monitoring and Evaluation
customer requirements such as Internal Audit
and Statistical Techniques. The resulting i. Quarterly, bi-annual and annual
information is reported to top management to reports to Ministry responsible for
assist in decision making process. Health and any other relevant
government institution
Performance indicators have been established
for everyNMRA processes and are periodically ii. Review of NMRA’s performance
analysed to determine whether the set targets during the Annual Joint Review
for the key results areas have been achieved. Mission and the National Health
If the planned results are not achieved, Assembly (Partners review).
correction and corrective action are taken to
ensure the product conformity. c) External Monitoring and Evaluation
Three approaches will be used for monitoring i. External audits ( e.g. ISO 9001
and evaluation in assessing the NMRA certification)
performance with respect to the processes
namely; self-reviews (internal), supervisory ii. Statutory audits (e.g. from auditor
body reviews (sectoral) and peer reviews general)
(external).
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In the event of process nonconformity, The NMRA keep records that indicate the
appropriate actions are taken to eliminate person(s) authorizing release of product
the cause of the nonconforming process and for delivery to the customer. The release
evaluate whether the process nonconformity of product and delivery of service to the
has resulted in product nonconformity. If customer does not proceed until the
product nonconformity has resulted this planned arrangement has been satisfactorily
product is identified and controlled according completed, unless otherwise approved by a
to documented procedures (State the SOP relevant authority and, where applicable, by
number). the customer.
Products are withheld from further processing Parties requiring notification of nonconforming
until there is objective evidence that the product may include suppliers, internal
required inspection and test have been organizations, customers, distributors, and
performed. relevant government agencies.
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suitability, effectiveness and opportunities data, corrective and preventive actions and
for improvement of the quality management management review.
system. The data analysis objectives for
NMRA are: The NMRA’s continual improvement is:
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The NMRA takes action to eliminate the root Records of results taken are maintained by
causes of nonconformities in order to prevent the respective directorates.
recurrence.
Non-conformities are analysed to determine
Records of corrective action taken are the preventive actions needed to avoid
maintained by the respective departments their occurrence. The analysis may include
the review of the dispositions taken on
8.5.3 Preventive action nonconforming products, observations
during internal and customer audits, trends
The NMRA determines action to eliminate the in rejection reports and product returns, and
causes of potential nonconformities in order customer complaints.
to prevent their occurrence. A documented
procedure for preventive action (state the The depth of the analysis is related to the
SOP number) has been established to criticality of the nonconformity, the impact on
define requirements for determining potential performance, reliability, customer satisfaction,
nonconformities and their causes, evaluating safety and the risk involved. Relevant
the need for action to prevent occurrence information on preventive actions taken is
of nonconformities, determining and submitted for management review.
implementing action needed, and reviewing
the effectiveness of the preventive action
taken.
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It is the policy of East African Community National Medicines Regulatory Authorities (NMRAs)
to ensure safe, quality and efficacious pharmaceuticals and related technologies that satisfy
customers while meeting statutory and regulatory requirements.
NMRAs are committed to continually improving the effectiveness of the QMS through customer
focus, teamwork; and provision of adequate financial, human, physical and technological
resources.
To ensure customer and statutory requirements are met, top management establishes Quality
objectives at relevant functional levels.
This quality policy and objectives shall be communicated to all NMRA staff and shall be reviewed
periodically for continuing suitability.
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7.2.1.2 SOPs developed for use within 7.2.3.1 SOPs must be assigned code
Directorates shall be initiated by numbers on the header provided on
Department Managers or any other every page of the SOP.
person within the NMRA as
appropriate a Manager will allocate 7.2.3.2 SOP numbers must be in the format
one of the future users to prepare it. MRAS/Directorate/Department/
SOP/xxx, where xxx is the serial
7.2.1.3 SOPs developed for use between number.
Directorates must be prepared by
respective Director, checked by 7.2.3.3 The SOP number must not be
HQM and authorized by Head changed even if the version has
NMRA (HNMRA). been changed.
7.2.2.1 SOPs must be written 7.2.5.2 Copies of the original SOPs shall
using Bookman Old Style as bear a blue ink stamp with the
follows: (font type and size may vary words “Controlled Copy” and should
from one NMRA to another) indicate a copy number.
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7.3.1.4. For extra ordinary meetings 7.4.4 The main contents of guidelines,
numbering will be the same except manuals and policies must be as
“Type & # of meeting” shall be shown in Addendum 6.
replaced by “Ex-MN. 1” for
Management meetings, “Ex-MT. 7.4.5 Guidelines, manuals and policies
1” for Board of Directors meetings must be numbered in the format
and “Ex-BOD.1” for BOD meetings. NMRAS/Directorate/Department/
Guideline, Manual or Policy/xxx,
7.3.1.5. Various committees shall follow the where xxx is the serial number (e.g.
same numbering system as NMRAS/DLS/TS/G or M or P/002).
prescribed in 6.1.5
7.4.6 The number must be bolded, itali
7.3.1.6 Numbering in between the texts cized and positioned on top and far
shall be as follows: right of the title page.
a) 1.0, 2.0, etc for major headings. 7.4.7 The full address of the Authority
must be printed at the bottom of the
b) 1.1, 1.2, 1.2.1 etc for sub headings title page (Addendum 5).
followed by a, b, c… and i, ii, iii(The
numbering may differ so long as 7.4.8 Copyright remarks must be shown
there is consistency) at the bottom of the back page of
manuals and/or policies
7.3.1.7 Bullets must not be used for (Addendum 5).
numbering items of minutes, SOPs
and any other documents. 7.4.9 The name of the document must be
written on the header of every
7.4 Guidelines, Manuals and policies page (except title page) and page
numbers formatted at the centre of
7.4.1 Draft guidelines, manuals and the page.
policies shall be prepared by
user directorate, reviewed by 7.4.10 The date of approval of the docu
relevant Technical Committee ment must be indicated at the bot
or a special committee formed for tom of the front page.
that particular purpose, checked by
HQM and approved by HNMRA. 7.4.11 The revision of guidelines, manuals,
and policies are subject to the same
7.4.2 All draft guidelines, manuals and review and approval process of the
policies intended to be used by original document.
customers shall be presented to
relevant stakeholders for their 7.4.12 The guidelines, manuals and
feedback before approval policies shall be reviewed after
every two years or when need
7.4.3 All guidelines, manuals and policies arises.
must have a title page as shown
in Addendum 5.
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7.4.13 The approval, review, effective date 7.4.20 Authorized MS Word documents
and revision number of the must be converted to PDF/A file
guidelines, manual and policy shall and stored in the central server
be indicated in the header as per and hard copies made available in
Addendum 2. the library.
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9.3 “Checked by”: Endorsement 9.6 “Effective Date”: A date after the
signifying that the internal document concerned staff or persons have
is ready for authorization. been formally trained on the use of
the document and training
9.4 Controlled Document”: document records maintained, but shall not be
which is distributed to pre-deter later than 10 working days from the
mined persons or staff and if any revision date.
change or revision is made on the
document, the Head Quality 9.7 “External Document”:
Management shall submit the
revised document and make sure a) A legal, regulatory or technical
that the previous (superseded) document which is not written or
document is retrieved. created (not internally generated),
issued or revised by NMRA.
9.5 “Document”:
b) “External document” can be used
a) “Document” means readable as reference in writing internal docu
information and its supporting ments or as a manual for operating
medium. equipment.
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REVISION HISTORY
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1. Header
6.1 Describes in detail what to do, how Identify and define frequently used terms or
to do and where to record acronyms. Provide additional and/or relevant
information needed to understand this SOP.
6.2 Procedure must be clear and under
standable 10. Revision History
6.3 It should have no or less Describe the changes made to the SOP
abbreviations
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EAC NMRA
NAME OF DOCUMENT
Date of Approval
P. O. Box 77150, EPI Mabibo, Off Mandela Road, Dar es Salaam, Tel: +255-22-
2450512/2450751/ 2452108, Fax: +255-22-2450793,
Website: www.EAC NMRAs.or.tz,
Email: info@EAC NMRAs.or.tz
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Back Page
This is a controlled document. It must not be copied without authorization from the Manager
Quality Management or Director of Business Support or Director General. Only originals or
authorized copies shall be used as working documents.
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2. Abbreviations
3. Acknowledgements
4. Preface
7. Introduction
8. Objectives
9. Scope
11. References/Bibliography
13. Annexes
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Addendum 8
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5.2.7 All soft copy of records shall be 5.3.4 The appraisal of records shall be
maintained in Management done after every three to five
Information System (MIS) database (according to national laws) years.
or any other system in place.
5.4 Protection
5.2.8 Records maintained in electronic
media shall be subjected to back-up 5.4.1 Records shall be maintained
and the back-up information indelibly. Any person initiating a
shall be stored in a protected and correction shall cross the wrong
secured management information information and insert the correct
system database (MIS) or any other one and then write his/her initials
system in place. and date where change was made.
The alteration should permit the
5.2.9 Only authorized personnel shall reading of the original information;
access records in hard and soft where appropriate the reason for
copy form. the alteration should be recorded.
5.2.10 The NMRA shall observe restrictions 5.4.2 The use of erasing fluid or any other
on access to information, under means of rendering information
the provisions of the law, with the illegible is forbidden.
aim to protect confidential
information, private life of a person, 5.4.3 Approved records shall not
and national security, as well as to be changed.
ensure the security of information
he/she is responsible for from 5.4.4 Records shall not be exposed to
unauthorized access, modification any agent of deterioration.
or damage.
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5.5.2 All records shall be organized and 5.7.3 Computer generated records shall
stored with a record index to allow be erased from the computer media.
retrieval in a timely manner.
5.7.4 Backup information for soft copy
5.5.3 General records at the registry shall records shall be retained for
be retrieved by the registry staff reference purpose.
on request
5.8 Records Issued to customers
5.5.4 Confidential human resources
records shall be retrieved by the 5.8.1 All copies of records issued to
Personal Assistant to the Director customers shall be maintained in
General. their respective customers file at
the registry.
5.6 Retention time
5.8.2 Customers shall be informed to
5.6.1 Unless specified otherwise in the keep records issued to them
respective procedures all records protected for the whole period of
shall be retained for a period of validity of the record and then return
five years. them once they have expired.
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Import and Export approval of Registry and MIS database Hard and softcopy 5 years
food, medicines, cosmetics and
medical devices
Premises registration records Registry and MIS database Hard and soft copy 5 years
Disposal of food, medicines, Registry and MIS database Hard and softcopy 5 years
medical devices and cosmetics
Inspection of medicines, medical Registry and MIS database Hard and softcopy 5 years
devices and cosmetics
Medicines, cosmetics and medical Registry, Dossier room and Hard and softcopy 5 years
and devices registration MIS database
Clinical trials assessment Registry and respective Hard and softcopy 5 years
department
Corrective & Preventative Action Quality Department and Hard and soft copy 5 years
registry
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The procedure applies to all internal quality Auditor/audit team is responsible for:
audits carried out in the NMRA.
a) Arranging a suitable time for the
3. Responsibility audit with the representative.
Head Quality Management is responsible for: b) Reviewing the SOP and from this
developing an audit checklist.
a) Planning for and scheduling audits
covering all elements of the QMS c) Completing the audit and audit
covering both management and report.
technical aspects) to be undertaken
within a one year’s audit cycle.
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The Auditee is responsible for cooperating audit schedule and for supporting the
with the auditor, and for providing information implementation of corrective and preventive
and resources necessary to achieve the actions as required
objectives of the audit.
4. Distribution List
The section owner of the audited organization
is responsible for taking appropriate and The distribution as per the procedure for
timely corrective action on any non-conformity control of documents.
identified during the audit.
5. Procedure
The Head of NMRA (HNMRA) is responsible
for authorizing the annual internal quality 5.1 Diagram of internal quality audit process
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8. Definitions, acronyms
and Abbreviations
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Annex 1
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Annex 2
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Annex 3
OPENING/CLOSING MEETING
DATE:
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Annex 4
AUDIT REPORT
DATE:
AUDIT REPORT NO:
1. BACKGROUND
1.1 Auditee
1.2 Auditors
1.3 Audit Criteria
1.4 Purpose of the Audit
1.5 Scope of Audit
1.6 Audit Sampling
1.7 Persons Contacted during the audit
1.8 Summary of Audit
2. FINDINGS
Clause/ Evidence Manual/ NC/OFI
Standard Procedure
4. RECOMMENDATION
5. CONCLUSION
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Representative: …………………………………………………………………………………….…..........
Auditor(s): …………………………………………………......................................................................
Assessor(s):…………………………………………..........................................................................….
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Date: …………/…………/……………..
Details ( as necessary):
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EAC/TF-MED/
QMS/FD/SOP/ Sign ……… Sign ……... Sign ……….. DD/MM/YY DD/MM/YY
N4R0 Date .......... Date .......... Date ..........
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e) All Staff (outlook copy) The HQM shall review the non-
conforming product and verify
5. Procedure whether it is significant or not. If
the nonconformity is significant, he/
Identification she shall assign an auditor/
investigator to undertake
5.1.1 Non-conforming products can be the investigation.
detected through internal or
external customer complaints, third Investigation
party audits, internal audit, data
analysis, customer satisfaction 5.1.6 The assigned auditor shall conduct
surveys, relevant Quality a full investigation to determine
Management Systems (QMS) the root cause and corrective
records and process measures to be undertake. A report
measurements. shall be prepared using internal
audit report F04/HNMRA/QM/
Reports of non-conforming products SOP/003 (Annex 1) and submitted
may result from external audits or to the HQM.
may occur as part of routine
operations, where an individual or Decision
department may identify a
non-conformance. The report shall be discussed between the
HQM and the responsible Supervisor/Head
5.1 Recording non-conforming of department and decision arrived at. Where
products applicable, the Head NMRA may be consulted
for further guidance and decisions as may
5.1.4 Non-conforming products identified be necessary.
during auditing shall be treated
as defined in the procedure for
conducting internal audit
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6. Records 7. References
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F01/HNMRA/QM/SOP/004
Rev #: 01
NON CONFORMANCE INVESTIGATION FORM
Is non-conformance significant?
Yes No
If yes go to part 4.
Comments by HQM:
………………………………..…. ………………………………..
Signature of MQM Date
Part 4: Auditor/Investigator
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EAC/TF-MED/
QMS/FD/SOP/ Sign ……… Sign ……... Sign ……….. DD/MM/YY DD/MM/YY
N5R0 Date .......... Date .......... Date ..........
f) All Staff
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5.9 The sample or exhibits shall 5.13 The investigation team shall
be preserved throughout the period collect all available evidence, (oral,
of investigation of the complaint. written, primary, secondary), and
ensure that all relevant information
5.10 The head of quality management is obtained and recorded during the
shall send the complaints to the investigation and that the chain of
relevant units/ department evidence is maintained.
responsible for the investigation of
the complaint 5.14 Depending on the nature of
the suspected defect and product,
Investigation of Customer Complaints and the complexity of any further
testing or investigation, it may take
5.11 The relevant department/unit. several weeks before any
shall initiate the investigation of the conclusions can be drawn.
complaint within 72 hours of
receiving the complaint to 5.15 On conclusion of the investigation,
investigate the complaint. the investigation team shall:
The Head of the Department or a) Carry out a root cause analysis and
Unit shall assign an investigation establish the root cause of the
team to undertake the investigation problem
of the reported complaint.
b) Write a detailed report to the Head,
5.12 Persons on the investigation NMRA with recommendations on
team shall not have been involved corrective and preventive actions to
in the original activities in question be taken.
or dispute if their presence may
affect the outcome of the 5.16 The Management team shall,
investigations. review the report of the investigation
team and resolve on the appropriate
In investigating the complaint, action to be taken.
the investigation team shall
determine the following: 5.17 Where the investigation report
is found to be inadequate or
incomplete in resolving the
complaint, the Head, NMRA shall
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defer the report and refer the matter 5.21 The head of NMRA with the
back to the investigation team or technical input from the investigation
appoint another investigation team team, relevant departments and the
to handle the complaint. Legal Services Unit shall set up
an Appeal Panel to review and
Resolution of a Complaint and Feedback to analyze the appeal.
the Complainant
5.22 The Appeals Panel shall not
5.18 When a complaint has been comprise of individuals or persons
resolved, NMRA shall take the who were involved in the original
following actions: activities in question or dispute.
a) Implement the corrective and/ 5.23 The Appeals Panel shall review the
or preventive actions as per existing and any new evidence/
procedure for Corrective and information and determine if there
preventive Action (refer Doc. No. is sufficient objective evidence to
*****) justify the appeal and shall report its
findings to Management team
b) Communicate to the complainant, in for hearing.
writing, the outcome of the
investigation and the actions taken. 5.24 If the Appeal Panel is appointed
by the NMRA’ s Board then the
c) Advise the complainant to undertake Panel shall report its findings to the
an appeals process within 14 Board, which will then communicate
working days in case of the final decision to the head of
dissatisfaction with the outcome of NMRA for action.
the investigation.
5.25 The head of NMRA shall then
d) Where necessary, arrangements for communicate the decision to the
following-up of any necessary appellants and those in dispute,
corrective and/or preventive actions in writing.
shall be discussed with the
complainant and documented. 5.26 Where no further action is raised
from the appellant or disputing party
Disputes and Appeals concerning the decision within
21 working days, NMRA will
5.19 Where a complaint is not resolved presume the decision to be
to the satisfaction of the satisfactory to the client and
complainant, he/she may appeal the file will be closed by the Head
the decision. Quality Management
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6.1 Complaints received at Branches, 7.2 The results of data analysis shall
shall be register and submit a be one of agendas in management
periodic reports shall be sent to review meeting(s).
the head NMRA by the Branch
managers except for those 8. Records
complaints that are beyond their
authority levels particularly policy The records include completed customer
related issues. Such complaints complaint form, customer complaint register
shall be forwarded to the head of and complaints analysis form and shall be filed
NMRA at the headquarters for in customer complaints file and maintained at
action as per clause 7. the register for a period of five years and then
disposed off by tearing/burning/shredding or
6.2 At Branch level, Branch manager any other appropriate method.
shall review the complaint and
conduct investigation (if necessary) 9. References
and communicate the outcome to
the complainant. EAC QMS Requirements
6.3 Depending on the outcome of the ISO 9001:2008; Quality Management Systems
investigations, the Branch manager Requirements (Fourth edition 2008-11-15)
may take corrective action.
ISO/IEC 17020:2012; conformity assessment-
6.4 In case the complainant is not requirements for the operation of various types
satisfied with the outcome/ feedback of bodies performing inspections
on the complaints submitted, the
complainant may appeal to the head EAC NMRA Quality Manual
of NMRA.
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EAC/TF-MED/
QMS/FD/SOP/ Sign ……… Sign ……... Sign ……….. DD/MM/YY DD/MM/YY
N7R0 Date .......... Date .......... Date ..........
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6.1.2 HQM shall issue CA number and 6.4 Verify and validate
assigns the identified CA to the
responsible department 6.4.1 The HQM shall verify and
investigation team which shall validate the Corrective action for
investigate the root cause of purposes of monitoring the
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6.13.1 The HQM shall ensure that • Opportunity: any situation that has
information related to the detected potential to be a problem or an
non-conformity and preventive improvement.
action(s) taken is disseminated to
those directly responsible for • Preventive Action: an action
assuring the quality of the taken to eliminate the cause of
concerned products or services. a potential nonconformity, defect or
other undesirable situation in order
6.14 Management Review to prevent recurrence.
6.14.1 The HQM shall submit relevant • Root Cause Analysis: Root cause
information on implementation of PA analysis is a method used to identify
to the management review the immediate, underlying and root
causes of an incident. The root
6.15 Preventive Action Closure causes are then used to
recommend remedial action that
6.15.1 PA shall be closed as per PA will prevent incidents of a similar
request form. nature taking place in the future.
6.16 Records
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8. Amendment/Revision History
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The HNMRA is responsible for implementing 5.4 HQM shall draw up agenda for
the resolutions which are made in the meeting. each meeting, which shall include
assessing opportunities for
It is the responsibility of Head Quality improvement and the need for
Management (HQM) to schedule the meeting, changes to the quality management
to prepare the agenda and ensure that system, including the quality policy
meetings are held as planned. and quality objectives.
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deemed necessary, at least two 5.8 The HQM shall record Improvement
weeks before the date of items related to QMS, products
the meeting or services provided or resources
needed shall be recorded as
5.6 During the management review Action Items in the meeting minutes
meeting, the information to be together with identification
presented shall include: of the responsible officers in charge
of implementation or further
5.6.1 results of internal and external investigations.
quality audits,
5.5 Minutes and action items shall be
5.6.2 Customer feedback (complaints, recorded in the management review
compliments, suggestions, etc.) meeting reporting form (indicate
form number)
5.6.3 key performance indicators for the
regulatory processes , 6 Records
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NMRAs
NMRA form no.
REV#: 0
…………………………………… ..……..………………………….........
Chairperson Secretary
………………………………...… …..…………………………………….
Date Date
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PART FIVE
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recognizing that the NMRA has l) Not solicit, force or accept bribes
placed trust and confidence onto from a person whom he/she is
him/her; serving, already served or will be
serving either by doing so himself/
d) Strive to acquire new knowledge herself or by using another person;
and skills continuously and use
them effectively; m) Not receive presents in form of
money, entertainments or any
e) Conduct medicines regulatory service from a person that may be
activities in a manner that will regarded as geared to
assure independence from outside compromising his/her integrity;
influence and interest, which would
otherwise compromise his/her ability n) Disclose fraud or abuse of power
to render a fair and impartial opinion and corruption to the top
regarding any medicines regulatory management of NMRA;
activity conducted;
o) Avoid the use of rude and abusive
f) Promptly disclose to the NMRA any language;
interest in any business related to
medicines which may affect p) Report findings truthfully
the quality, or the result of his/her and accurately;
work or remediation;
q) Make decisions in line with
g) Not use his/her position for authorized standards
personal gain; and procedures;
k) Assess facts quickly and take u) Adhere to the laid down laws,
rational and sound decisions regulations, rules and standard
without delay; operating procedures in executing
his/her functions.
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e) Not to use the information for a) was known to you prior to any
commercial purpose disclosure by or on behalf of the
NMRA (including by the
f) not to disclose or provide the manufacturer(s)); or
Information to any person who is not
bound by similar obligations of b) was in the public domain at the time
confidentiality and non-use as of disclosure by or on behalf of the
contained herein. NMRA (including the
manufacturer(s)); or
g) undertake not to communicate
your deliberations and findings c) becomes part of the public domain
and/or those of other employees, through no fault of your own; or
as well as any resulting
recommendations to, and/or d) becomes available to you from
decisions of, the NMRA to any a third party not in breach of any
third party, except as explicitly legal obligations of confidentiality.
agreed by the NMRA.
3.4. Continuing duty
h) To ascertain the provenance of the of confidentiality
party putting a question and when
needed for the party to put NMRA’s management board, advisory
in writing; committees, staff, other persons working for
the NMRA such as persons employed under
i) To apply common sense when private law contracts, experts on secondment,
answering indirect questions trainees and other relevant persons have a
seeking to obtain information life-long duty of confidentiality even after they
have ceased their relationship with the NMRA.
j) To follow a laid down procedures This covers all information of the kind covered
for handling of requests for access by the obligation of professional secrecy.
to information; NMRA staff are required to behave with
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integrity and discretion after leaving the NMRA 3.5. When is the NMRA personnel
for a period of two years following departure required to complete a
from the NMRA. Former NRMA staff should confidentiality undertaking
not exploit their relationship with former
form?
colleagues to obtain professional advantage
or information of a specific or regulatory nature
1. All NMRA personnel must
for personal advantage. NMRA shall apply a
complete Confidentiality
distance policy to former staff to ensure that its
Undertaking (CU) form (see Annex
interests are protected and that such problems
2) before their recruitment can
do not arise.
be confirmed and during the course
of employment.
Staff leaving the NMRA are able to use
the skills acquired in the course of their
2. Board members and advisory
employment at the NMRA so long as such
committee members shall complete
use is, for a period of two years, not in conflict
this form during their swearing in
with the legitimate interests of the service
ceremony and before any meeting.
and does not interfere with their obligation of
confidentiality.
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Completing this DOI form means that you 2. Form for Declaration
agree to these conditions. If you are unable or of Interest
unwilling to disclose the details of an interest
that may pose a real or perceived conflict, Please answer each of the questions below.
you must disclose that a conflict of interest If the answer to any of the questions is “yes”,
may exist and the NMRA may decide that you briefly describe the circumstances on the last
be totally excluded from the meeting or work page of the form. The term “you” refers to
concerned, after consulting with you. yourself and your immediate family members
(i.e., spouse or partner with whom you have
Where there is sufficient evidence that the a similar close personal relationship and your
NMRA personnel has conflict of interest children).
relevant to the NMRA and failed to disclose
such conflict of interest on the Declaration “Commercial entity” includes any
of Interest (DOI) form this may lead to commercial business, an industry association,
disciplinary action being taken against the research institution or other enterprise
concerned personnel. whose funding is significantly derived from
commercial sources with an interest related to
the NMRA.
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Within the past 4 years, have you received remuneration from a commercial entity or
other organization with an interest related to NMRA work?
Yes No
1a Employment
1b Consulting, including service as a technical or other advisor
Previous year: Yes No
More than 1 year ago but less than 3 years ago: Yes No
RESEARCH SUPPORT
Within the past 4 years, have you or has your research unit received support from a
commercial entity or other organization with an interest related to NMRA work?
Item Yes No
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INVESTMENT INTERESTS
Do you have current investments or business (valued at more than US$ 5000 overall) in
a commercial entity with an interest related to the NMRA? Please also include indirect
investments such as a trust or holding company. You may exclude mutual funds,
pension funds or similar investments that are broadly diversified and on which you
exercise no control.
Item Yes No
INTELLECTUAL PROPERTY
Do you have any intellectual property rights that might be enhanced or diminished by
working with the NMRA?
Item Yes No
Item Yes No
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ADDITIONAL INFORMATION
Item Yes No
6a If not already disclosed above, will your work enable you to obtain
access to a competitor’s confidential proprietary information, or
create for you a personal, professional, financial or business
competitive advantage?
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Nos. 5-6: Describe the subject, specific circumstances, parties involved, time frame and other
relevant details
DECLARATION
I hereby declare on my honor that the disclosed information is true and complete to
the best of my knowledge. Should there be any change to the above information, I will
promptly notify the NMRA and complete a new declaration of interest form that describes
the changes. This includes any change that occurs before or during the meeting or work
itself and through the period up to the publication of the final results or completion of the
activity concerned.
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....... In the course of discharging your functions as an NMRA staff, you will gain access
to certain information, which is proprietary to the NMRA or entities collaborating with
the NMRA, including the regulated industry. You undertake to treat such information
(hereinafter referred to as “the Information”) as confidential and proprietary to the NMRA
or the aforesaid parties collaborating with the NMRA. In this connection, you agree:
a) not to use the Information for any other purpose than discharging your employment
obligations; and
b) not to disclose or provide the Information to any person who is not bound by similar
obligations of confidentiality and non-use as contained herein.
However, you will not be bound by any obligations of confidentiality and non-use to the extent that
you are clearly able to demonstrate that any part of the Information:
a) was known to you prior to any disclosure by or on behalf of the NMRA [including by the
manufacturer(s)]; or
b) was in the public domain at the time of disclosure by or on behalf of the NMRA
[including the manufacturer(s)]; or
c) becomes part of the public domain through no fault of your own; or
d) becomes available to you from a third party not in breach of any legal obligations
of confidentiality.
You also undertake not to communicate your deliberations and findings and/or those of other
employees, as well as any resulting recommendations to, and/or decisions of, the NMRA to any
third party, except as explicitly agreed by the NMRA.
You will discharge your responsibilities under the terms of employment. In this connection, you
confirm that the information disclosed by you in the Declaration of Interest is correct and that no
situation of real, potential or apparent conflict of interest is known to you, including that you have
no financial or other interest in, and/or other relationship with, a party, which:
a) may have a vested commercial interest in obtaining access to any part of the
Information referred to above; and/or
b) may have a vested interest in the outcome of the evaluation of the product(s), in which
you will participate (such as the manufacturers of those products or of competing
products).
You undertake to promptly advise the NMRA of any change in the above circumstances, including
if an issue arises during the course of your employment with the NMRA.
I hereby accept and agree with the conditions and provisions contained in this document.
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