In this article, we will discuss a practical approach to prepare the Site Master File (SMF) for the Pharmaceutical Industry.
We have to understand that The SMF is the document which explains your organization; it creates the image of the organization, So it should be self-explanatory as in most of the case you are not present to explain the SMF.
Do you believe that the SMF is creating the first impression of your organization before visiting your Site…
After discussing with various regulatory authorities and Customers to whom the organization is submitting their SMF; I have noticed their concern related to SMF and I am summarizing the same here.
What is SMF?
Why SMF is Require?
Who should prepare the SMF?
When the SMF should be prepared?
For Whom the SMF should be prepared?
How to prepare the SMF?
What is SMF?
The site master file (SMF) is prepared by the pharmaceutical manufacturer and should contain specific information about the quality management policies and activities of the site, the production and/or quality control of pharmaceutical manufacturing operations carried out at the named site, and any closely integrated operations at adjacent and nearby buildings. if only part of a pharmaceutical operation is carried out on the site, the SMF need only describe those operations, e.g. analysis, packaging, etc.
Why SMF is Require?
- SMF is a regulatory requirement and it belongs to Quality System
- For business purpose; it is representative of the organization
Who should prepare the SMF?
The SMF should be prepared by the organization that is involved in manufacturing operations such as production, packaging and labeling, testing, relabelling, and repackaging of all types of medicinal products. It should be also prepared by blood and tissue establishments and manufacturers of active pharmaceutical ingredients (APIs).
When the SMF should be prepared?
Initially at the time of the establishment of the organization, as and when change in the content of the SMF, or any revision in the Guideline.
For Whom the SMF should be prepared?
Represent the organization to Regulatory Authority and customer
How to prepare the SMF?
The perfect guidance is provided in three major guidelines of pharmaceutical regulatory as follows;
EudraLex; Volume 4; Explanatory Notes on the preparation of a Site Master File (Year:2011)
PIC/S; PE 008-4; EXPLANATORY NOTES FOR PHARMACEUTICAL MANUFACTURERS ON THE PREPARATION OF A SITE MASTER FILE (Year:2011)
WHO; Technical Report Series, No.961; Annex 14, WHO guidelines for drafting a site master file (Year:2011)
Above all three guidelines are the same, so it is easy to prepare the SMF without confusion.
General considerations:
The Site Master File is prepared by the pharmaceutical manufacturer and should contain specific information about the quality management policies and activities of the site, the production and/or quality control of pharmaceutical manufacturing operations carried out at the named site, and any closely integrated operations at adjacent and nearby buildings. If only part of a pharmaceutical operation is carried out on the site, a Site Master File need only describe those operations, e.g. analysis, packaging, etc.
When submitted to a regulatory authority, the Site Master File should provide clear information on the manufacturer’s GMP-related activities that can be useful in the general supervision and in the efficient planning and undertaking of GMP inspections.
A Site Master File should contain adequate information but, as far as possible, not exceed 25-30 pages plus appendices. Simple plans outline drawings or schematic layouts are preferred instead of narratives. The Site Master File, including appendices, should be readable when printed on A4 paper sheets.
The Site Master File should be a part of documentation belonging to the quality management system of the manufacturer and kept updated accordingly. The Site Master File should have an edition number, the date it becomes effective, and the date by which it has to be reviewed. It should be subject to regular review to ensure that it is up to date and representative of current activities. Each Appendix (Annex) can have an individual effective date, allowing for independent updating.
The Site Master File is useful to the regulatory authority in planning and conducting the GMP inspections.
CONTENT OF SITE MASTER FILE
1. General information on the manufacturer
1.1 Contact information on the manufacturer
— name and official address of the manufacturer;
— names and street addresses of the site, buildings, and production units located on the site;
— contact information of the manufacturer including the 24-hour telephone number of the contact personnel in the case of product defects or recalls; and
— identification number of the site as e.g. global positioning system (GPS) details, D-U-N-S (Data Universal Numbering System) number (a unique identification number provided by Dun & Bradstreet) of the site or any other geographical location system.
1.2 Authorized pharmaceutical manufacturing activities of the site
— copy of the valid manufacturing authorization issued by the relevant competent authority in Annex 1; or when applicable, reference to the EudraGMP database. If the competent authority does not issue manufacturing authorizations, this should be stated;
— brief description of manufacture, import, export, distribution, and other activities as authorized by the relevant competent authorities including foreign authorities with authorized dosage forms/activities, respectively; where not covered by the manufacturing authorization;
— type of products currently manufactured on-site (list in Annex 2) where not covered by Annex 1 or the EudraGMP database; and
— list of GMP inspections of the site within the last five years; including dates and name/country of the competent authority having performed the inspection. A copy of the current GMP certificate (Annex 3) or reference to the EudraGMP database should be included, if available.
1.3 Any other manufacturing activities carried out on the site
— description of non-pharmaceutical activities on-site, if any.
2. Quality management
2.1 The quality management system of the manufacturer
— brief description of the quality management systems run by the company and reference to the standards used;
— responsibilities related to the maintaining of the quality system including senior management; and
— information on activities for which the site is accredited and certified, including dates and contents of accreditations, and names of accrediting bodies.
2.2 Release procedure of finished products
— detailed description of qualification requirements (education and work experience) of the authorized person(s)/qualified person(s) responsible for batch certification and releasing procedures;
— general description of batch certification and releasing procedure;
— role of the authorized person/qualified person in quarantine and release of finished products and in the assessment of compliance with the marketing authorization;
— the arrangements between authorized persons/qualified persons when several authorized persons/qualified persons are involved; and
— statement on whether the control strategy employs process analytical technology (PAT) and/or real-time release or parametric release.
2.3 Management of suppliers and contractors
— a brief summary of the establishment/knowledge of the supply chain and the external audit program;
— a brief description of the qualification system of contractors, manufacturers of APIs, and other critical materials suppliers;
— measures taken to ensure that products manufactured are compliant with transmitting animal spongiform encephalopathy (TSE) guidance;
— measures adopted where substandard/spurious/falsely-labeled/falsified/counterfeit medical products, bulk products (i.e. unpacked tablets), APIs or excipients are suspected or identified;
— use of outside scientific, analytical, or other technical assistance in relation to manufacture and analysis;
— list of contract manufacturers and laboratories including the addresses and contact information and flowcharts of supply chains for outsourced manufacturing and QC activities, e.g. sterilization of primary packaging material for aseptic processes, testing of starting raw materials, etc., should be presented in Annex 4; and
— brief overview of the responsibility-sharing between the contract giver and acceptor with respect to compliance with the marketing authorization (where not included under 2.2).
2.4 Quality risk management
— brief description of quality risk management (QRM) methodologies used by the manufacturer; and
— scope and focus of QRM including a brief description of any activities which are performed at the corporate level, and those which are performed locally. Any application of the QRM system to assess continuity of supply should be mentioned.
2.5 Product quality reviews
— brief description of methodologies used.
3. Personnel
— organization chart showing the arrangements for quality management, production, and quality control positions/titles in Annex 5, including senior management and authorized person(s)/qualified person(s); and
— number of employees engaged in the quality management, production, quality control, storage, and distribution, respectively.
4. Premises and equipment
4.1 Premises
— short description of plant: the size of the site and list of buildings. If the products for different markets, i.e. for the local country or regional economic areas, take place in different buildings on the site, the buildings should be listed with destined markets identified (if not identified under 1.1);
— simple plan or description of manufacturing areas with an indication of scale (architectural or engineering drawings are not required);
— layouts and flowcharts of the production areas (in Annex 6) showing the room classification and pressure differentials between adjoining areas and indicating the production activities (i.e. compounding, filling, storage, packaging, etc.) in the rooms;
— layouts of warehouses and storage areas, with special areas for the storage and handling of highly toxic, hazardous, and sensitizing materials indicated, if applicable; and
— brief description of specific storage conditions if applicable, but not indicated on the layouts.
4.1.1 Brief description of heating, ventilation, and air-conditioning (HVAC) systems
— principles for defining the air supply, temperature, humidity, pressure differentials and air-change rates, the policy of air recirculation (%).
4.1.2 Brief description of water systems
— quality references of water produced; and
— schematic drawings of the systems in Annex 7.
4.1.3 Brief description of other relevant utilities such as steam, compressed air, nitrogen, etc.
4.2 Equipment
4.2.1 Listing of major production and control laboratory equipment with critical pieces of equipment identified should be provided in Annex 8.
4.2.2 Cleaning and sanitation
— brief description of cleaning and sanitation methods of product contact surfaces (i.e. manual cleaning, automatic clean-in-place, etc.).
4.2.3 Good manufacturing practices critical computerized systems
— description of GMP critical computerized systems (excluding equipment-specific programmable logic controllers (PLCs)).
5. Documentation
— description of documentation system (i.e. electronic, manual); and
— when documents and records are stored or archived off-site (including pharmacovigilance data, when applicable): list of types of documents/records; name and address of storage site; and an estimate of the time required to retrieve documents from the off-site archive.
6. Production
6.1 Type of products
References to Annex 1 or 2 can be made.
— type of products manufactured including:
• list of dosage forms of both human and veterinary products which are manufactured on the site
• list of dosage forms of investigational medicinal products (IMP) manufactured for any clinical trials on the site, and when different from the commercial manufacturing, information on production areas and personnel;
— toxic or hazardous substances handled (e.g. with high pharmacological activity and/or with sensitizing properties);
— product types manufactured in a dedicated facility or on a campaign basis, if applicable; and
— PAT applications, if applicable: a general statement of the relevant technology; and associated computerized systems.
6.2 Process validation
— brief description of general policy for process validation; and
— policy for reprocessing or reworking.
6.3 Material management and warehousing
— arrangements for the handling of starting materials, packaging materials,
bulk and finished products including sampling, quarantine, release, and storage; and
— arrangements for the handling of rejected materials and products.
7. Quality control
— description of the QC activities carried out on the site in terms of physical, chemical and microbiological, and biological testing.
8. Distribution, complaints, product defects, and recalls
8.1 Distribution (to the part under the responsibility of the manufacturer)
— types (wholesale licence holders, manufacturing licence holders, etc.) and locations (countries or regional economic areas) of the companies to which the products are shipped from the site;
— description of the system used to verify that each customer/recipient is legally entitled to receive medicinal products from the manufacturer;
— brief description of the system to ensure appropriate environmental conditions during transit, e.g. temperature monitoring/control;
— arrangements for product distribution and methods by which product traceability is maintained; and
— measures are taken to prevent manufacturers’ products entering into the illegal supply chain.
8.2 Complaints, product defects, and recalls
— brief description of the system for handling complaints, product defects, and recalls.
9. Self-inspections
— short description of the self-inspection system with a focus on criteria used for selection of the areas to be covered during planned inspections, practical arrangements, and follow-up activities.
Annexes to submission of a site master file
Annex 1 Copy of valid manufacturing authorization
Annex 2 List of dosage forms manufactured including the International Nonproprietary
Names (INN) or common name (as available) of APIs used
Annex 3 Copy of valid GMP certificate
Annex 4 List of contract manufacturers and laboratories including the addresses and contact
information, and flowcharts of the supply chains for these outsourced activities
Annex 5 Organizational charts
Annex 6 Layouts of production areas including material and personnel flows, general
flowcharts of manufacturing processes of each product type (dosage form)
Annex 7 Schematic drawings of water systems
Annex 8 List of major production and laboratory equipment
If you requireExample SMF; I will provide Sample SMF for OSD and the Injectable site.
you can write in the comment box for the same.
Dear readers; I am Inviting you to become a part of the DPT Family (Dynamic Pharma Team.
To update yourself; regularly visit our website: www.pharmaceuticalguideline.com and become a member (it's FREE) by clicking the Login button at the top right corner of the webpage, also subscribe to our newsletter, Like our website, follow us on
Telegram, Download Telegram App on your Mobile and use @pharmaceuticalguideline for search.
Your like is inspiring us to prepare the articles...
Please Inform me when Sample SMF is available for us
Thanks...