the abcs of the glps - revised

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    The ABCs of the GLPs

    Stacy Pritt, DVM, MBA, MS

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    Ou tline

    GL PsWhere can you get further information?

    You get to play QA!

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    The GLPs

    GL Ps = G ood Laboratory PracticesFederal regulations that describe how to

    conduct nonclinical laboratory studies thatsupport or are intended to supportapplications for research or marketingpermits for products regulated by the Foodand Drug Administration

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    GLP St ud ies Are NecessaryFor The Following Pro du cts:

    Food and color additives

    Animal food additivesHuman and animaldrugsMedical devices

    Biological productsElectronic products

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    FDA GLPs Come From:

    Federal Food, Drug, and Cosmetic ActOriginally implemented in 1978

    Updated periodicallyFDA is enforcing agency

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    Also Incl ud es.

    Some products (pesticides, insecticides, etc.)regulated by the EPA

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    W hy the GLPs?

    Problems in the past:Some safety assessments were based on poor quality studiesStudy protocols and records were not alwayslocatedDetails of procedures were inadequate

    Qualifications of personnel and training recordswere not always available

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    The GLPs

    Code of FederalRegulationsTitle 21 Food andDrugsPart 58 G oodLaboratory Practices for Nonclinical LaboratoryStudies

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    Basic Req u irements

    Study ProtocolsStandard Operating Procedures (SOPs)

    Trained personnel familiar with the testingmethodologies Adequate facilities and equipment, equipmentmaintenance

    Full identification of test substanceProper Animal Care (vs. Animal Welfare)

    Accurate recording of observations and reportingof results

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    Basic Definitions

    Nonclinical laboratory study In vivo or In vitroexperiments in which test articles are studiedprospectively in test systems under laboratory

    conditions to determine their safety; does notinclude human studies, animal field trials, or chemical testsStudy Director Individual responsible for theoverall conduct of a nonclinical laboratory studySponsor

    Initiator (by financial or other resources) of a nonclinicalstudySubmitter of a study to the FDA

    Testing facility if it initiates and conducts the study

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    Basic Definitions

    Quality Assurance Unit Any person or organizational element (except SD)

    designated by the testing facilitymanagement to perform the qualityassurance of a nonclinical laboratory studyProtocol Procedures for the study

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    Basic Definitions

    Test System Animal, plant, microorganisms, or subpartsreceiving administration of test or control article

    Test Article Any article subject to regulationunder the FDAControl Article Article administered to a testsystem for the purpose of establishing abasis for comparison with the test articleTesting Facility Facility that conducts anonclinical study and is required to register

    with the FDA

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    Basic Definitions

    Raw DataLaboratory worksheets

    RecordsMemorandaNotesOr exact copies that are the result of original

    observations and activities of the study necessaryfor the reconstruction and evaluation of the reportof that study

    Animal cage cards?

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    Areas of the GLP Reg u lations

    G eneral Provisions, Organization, &Personnel

    Facilities & EquipmentTesting Facility Operations andTest, Control, and Reference

    SubstancesProtocol for the Conduct of a Study, Reports,and Records

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    Life Cycle of a GLP St ud y

    Protocol Report

    QAU

    Study Director, Testing Facility Management

    FDA/EPA

    Sponsor

    Nonclinical Laboratory Study

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    Sponsors & Facilities

    Sponsors have a product they want to sellLarge Pharma

    Medical DeviceStart-up biotech/pharma

    Sponsors may not be the testing acility if:They have inadequate facilities and/or expertiseWant independent verification of their dataThe FDA has required them to seek an outsideopinion

    Contract Research Organizations

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    Responsibilities

    Study Director Protocol approval (including changes anddeviations during the course of the study)

    Accurate experimental data recording andverificationGL P standards are followed

    Submission of raw data, documentation,protocols, specimens, and final reports or archives at end of study

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    Responsibilities

    QAUMaintain a master schedule of all studiesconducted at the testing facilityMaintain all protocols and SOPsConduct inspections of studies to ensure integrityReview study reports for accuracy

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    FacilitiesSeparate areas for:

    Receipt and storage of test, control, andreference substances

    Conducting proceduresStorage of raw dataSeparation of animal species

    Animal food and bedding storage Animal food mixing

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    E q u ipmentEquipment shall be inspected, cleaned, andmaintained on a regular basisEquipment used for the generation,measurement, or assessment of data shall beadequately tested, calibrated, and maintainedWritten records of all testing, calibrating, and

    inspections shall be maintained

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    S O Ps

    Animal Care Animal room maintenance

    Test system preparation and receiptReceipt, identification, storage, and mixing of test, control, and reference substances

    NecropsyCollection and identification of specimensMaintenance and calibration of equipment

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    Animal Care

    SOPs for the housing, feeding, and care of animals must be maintainedSome requirements are:

    New animals must be quarantined or isolated andtheir health status evaluated prior to use

    Animals must be identified appropriately All housing areas must be kept clean andsanitized regularlyFeed and water should be analyzed periodically(every 6 months) and contaminant levelsmonitored and documented

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    M ore Information

    FDA Web siteEPA Web site

    Society for Regulatory Affairs Professionals AAL AS

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    Y o u Play QA!

    Read the Protocol

    See what is wrong on the data sheet