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Releasing medicines manufactured at multiple sites
Technical guidance on the interpretation of the PIC/S Guide to GMP
About this guidance
If you are a sponsor or manufacturer of a medicine manufactured across multiple sites, then this guidance will help you understand:
- release for further processing (RFFP) requirements
- how RFFP fits into the release for supply (RFS) process.
Read this guidance together with the general requirements and responsibilities of release for supply of medicines, which apply to Australian sponsors and all TGA licensed or certified manufacturers.
Release for further processing (RFFP)
RFFP refers to release of either:
- an intermediate or bulk product to the next manufacturer in the supply chain
- the finished product that requires alteration for distribution into the Australian Market.
Such arrangements are to be defined in GMP agreements.
Development of this guidance
We have developed this guidance to demonstrate how the release for supply process works across multiple sites of manufacture:
- in response to requests from industry for further guidance
- in consultation with experts from the relevant industry associations.
Scenarios to demonstrate RFFP and RFS
This guidance provides scenarios to help demonstrate some of the issues for consideration in order to meet the general RFS requirements, particularly for:
- specific areas of manufacture, for example listed and complementary medicines
- complex supply chains where manufacture occurs at multiple sites
This guidance is a living document. We can update it with scenarios that are more specific, where further interpretation is required. Any updates will only occur after appropriate consultation with the relevant stakeholders.
This information is provided for guidance only and has been developed on the basis of current knowledge of the subject matter. It should not be relied upon to address every aspect of the relevant legislation. Please also refer to the Therapeutic Goods Act 1989 and the Therapeutic Goods Regulations 1990 for legislative requirements and the current version of the PIC/S Guide to GMP.
This guidance is not mandatory or enforceable under law. It is not intended to be restrictive. We recommend following this guidance document to facilitate regulatory obligations being met. The guidance describes a way that a manufacturer may operate to demonstrate compliance with the relevant manufacturing principles (PIC/S Guide to GMP).
Guidance documents are not intended to establish a minimum standard of practice for inspection purposes. Guidance documents are not enforceable.
Content of this guidance
This guidance covers:
- how to meet RFS requirements when manufacturing at multiple sites, including:
- scenarios to demonstrate release for supply when manufacturing at multiple sites:
For information on release for supply of medicinal gases, refer to the medicinal gas guidance
- PIC/S Guide to GMP Part II: RFFP of active pharmaceutical ingredients and intermediates Section 6.7 Batch production record review