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Three Years Into Annex 1: What Inspectors Are Actually Asking For

In the pharmaceutical industry, contamination control is not just about meeting regulatory requirements. It determines whether product quality and patient safety can be demonstrated – and, in practice, whether a batch can be released and a facility can keep running.

Farma Consulting & Partners Normec Advipro
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Since the revised EU GMP Annex 1 became effective on 25 August 2023, and with PIC/S PE 009-17 aligning the same expectations across participating authorities, many organisations are facing the same recurring questions: 

  • Which contamination control requirements actually apply to our processes – and how do we evidence them? 
  • How do we keep cleanrooms, procedures and monitoring programmes compliant between qualifications, not only on the day of testing? 
  • What documentation, risk assessments and qualification strategies do inspectors actually expect to see? 
  • How do we deliver all of this without stopping production? 

This isn't only an industrial concern. Hospital pharmacies and compounding centers face a parallel shift under PIC/S PE 010-4, the guide for preparing medicinal products in healthcare establishments. In Belgium, it became binding for hospital pharmacies from 1 January 2026 under the Royal Decree of 30 September 2020, with FAGG inspectors assessing compliance directly. The same questions above apply here too, even outside the industrial GMP framework.