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Repackaging (revision 1)

Old revision·09:00, 30 Sep 2024·PrepHPLC_Pia

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Repackaging
OperationTransfer to a new container, or relabelling
RiskSevered traceability
MitigationNew record referencing the original lot
Topic infobox · conventions

Repackaging is the transfer of material from one container into another, or the relabelling of an existing container under a new identifier. It is a legitimate and common operation, and it is also the point at which lot traceability is most often lost.[1]

A repackager who assigns a new batch number without recording the original one has severed the link between the container and every determination ever made on the material. The resulting vial cannot be associated with any certificate, however genuine that certificate is.[2]

Why the record is the whole thing

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Nothing about repackaged material is detectable by analysis. A repackaged peptide is the same molecule, and a determination on it returns the same numbers; what has changed is what is known about where it came from.[2]

PracticeEffect on traceability
New identifier referencing the original lotPreserved
New identifier, original recorded internallyPreserved if records are retrievable
New identifier, original not recordedSevered
Original identifier retainedPreserved, but may misattribute the repackaging step

References

  1. ^ International Council for Harmonisation, Q7: Good Manufacturing Practice Guide for Active Pharmaceutical Ingredients (2000).
  2. ^ a b ISO 9001:2015, Quality management systems — Requirements, clause 8.5.2.