New PIC/S recommendation for evaluating PQS effectiveness in relation to risk-based change management
On November 28, 2019 the Pharmaceutical Inspection Co-Operation Scheme (PIC/S) published a draft Recommendation for Participating Authorities, providing practical guidance for GMP inspectors, on how to evaluate the effectiveness of a pharmaceutical quality system (PQS) in relation to risk-based change management.(1)
The PIC/S GMP Guide requires companies to have an effective PQS and apply quality risk management (QRM) principles to change control activities.
Chapter 1 states:
· Principle: …there must be ‘a comprehensively designed and correctly implemented Pharmaceutical Quality System incorporating Good Manufacturing Practice and Quality Risk Management. It should be fully documented and its effectiveness monitored’.
· 1.3 ...’the effectiveness of the system is normally demonstrated at the site level’.
· 1.5 ‘Senior management has the ultimate responsibility to ensure an effective Pharmaceutical Quality System is in place...’
· 1.4 (xii) Arrangements [should be] in place ‘for the prospective evaluation of planned changes and their approval prior to implementation…’
Annex 15 states:
· 11.1. ‘The control of change is an important part of knowledge management and should be handled within the pharmaceutical quality system.’
· 11.4. ‘Quality risk management should be used to evaluate planned changes… and to plan for any necessary process validation, verification or requalification efforts.’
· 11.7. ‘…an evaluation of the effectiveness of change should be carried out…’
The recommendation was prepared by the PIC/S Expert Circle on QRM and does not create any new GMP requirements or expectations. It simply provides inspectors with a tool to support an evaluation of PQS effectiveness in relation to risk-based change management. It has been designed to help inspectors increase their understanding of what risk-based change management means at a practical level, and then give a framework to help see how effective implementation might be demonstrated by pharmaceutical companies. The tool provides a checklist approach focusing on:
· Change proposals – Determination of when a change is needed
· Change risk assessments
· Change Planning and implementation
· Change review and effectiveness
The recommendation is currently a draft that is being applied on a 6-month trial basis, with an expectation that formal adoption will subsequently occur on a revised version following comments on use of the tool by PIC/S participating authorities.
Of more significance than the use of the tool by inspectors over the coming months, is that this move starts to see a shift, albeit a small one, towards greater risk-based regulatory oversight as envisaged in ICH Q10 (Pharmaceutical Quality System) and Q12 (Lifecycle Management). (2)
(1) https://www.picscheme.org/en/news
(2) https://www.ich.org/page/quality-guidelines
Related Insights
Case Study
Speed meets strategy: Delivering a critical FDA 1572 package in just seven days
Sep 9, 2026
Blog
Actioning the commitment letter: The PDUFA VIII changes that matter most to sponsors
Aug 25, 2026
Blog
Data without borders: Assessing China-only evidence for EMA approval – insights from ex-EMA and seasoned subject matter experts
Aug 19, 2026
Blog
The Next Frontier of ADC Development: Navigating an Evolving Regulatory Landscape
Aug 12, 2026
Webinar
From APAC to global: Designing data that travels
Jul 16, 2026
Blog
Regulatory submissions as a source of insight: How AI can amplify the value of our work
Jul 15, 2026
Blog
Accelerating first-in-human studies: Why the FDA’s Expedited IND pilot signals a new era for early development
Jul 6, 2026
CTB Blog
A credible global regulatory strategy is an early-phase imperative, not a late-stage commercial exercise
Jun 23, 2026
CTB Blog
Understanding FDA complete response letters: Why CMC readiness must become a strategic priority
Jun 18, 2026
Case Study
Case study: Repositioning first-in-human development at speed
Jun 8, 2026
Blog
Beyond participation: How EU HTA is turning patient and clinician engagement into evidence architecture
May 26, 2026
Playbook
JCA in the EU: A roadmap for health technology developers
May 15, 2026
Related Insights
Case Study
Speed meets strategy: Delivering a critical FDA 1572 package in just seven days
Sep 9, 2026
Blog
Actioning the commitment letter: The PDUFA VIII changes that matter most to sponsors
Aug 25, 2026
Blog
Data without borders: Assessing China-only evidence for EMA approval – insights from ex-EMA and seasoned subject matter experts
Aug 19, 2026
Blog
The Next Frontier of ADC Development: Navigating an Evolving Regulatory Landscape
Aug 12, 2026
Webinar
From APAC to global: Designing data that travels
Jul 16, 2026
Blog
Regulatory submissions as a source of insight: How AI can amplify the value of our work
Jul 15, 2026
Blog
Accelerating first-in-human studies: Why the FDA’s Expedited IND pilot signals a new era for early development
Jul 6, 2026
CTB Blog
A credible global regulatory strategy is an early-phase imperative, not a late-stage commercial exercise
Jun 23, 2026
CTB Blog
Understanding FDA complete response letters: Why CMC readiness must become a strategic priority
Jun 18, 2026
Case Study
Case study: Repositioning first-in-human development at speed
Jun 8, 2026
Blog
Beyond participation: How EU HTA is turning patient and clinician engagement into evidence architecture
May 26, 2026
Playbook
JCA in the EU: A roadmap for health technology developers
May 15, 2026

