A cold chain can be managed by a quality management system. It should be analyzed, measured, controlled, documented, and validated.
The overall approach to validation of a distribution process is by building more and more qualifications on top of each other to get to a validated state. This is done by executing a Component Qualification on the packaging components, an Operational Qualification to demonstrate that the process performs at the operational extremes and finally a Performance Qualification that demonstrates that what happens in the real world is within the limits of what was demonstrated in the Operational Qualification limits.
Performing thermal testing can also help with validating the cold chain. Certified test labs use environmental chambers to simulate ambient profiles that a package may encounter in the distribution cycle. Thermocouple probes and separate temperature dataloggers measure temperatures within the product load to determine the response of the package to the test conditions. Replicate testing based on a qualification protocols is used to create a final qualification report that can be used to defend the configuration when audited by regulators. It is normally best to have an individual that understands the principles of Validation, when defending such processes to a Federal Regulatory body of any nation.
Cold chains need to be evaluated and controlled:
Carriers and logistics providers can assist shippers. These providers have the technical ability to link with airlines for real time status, generate web-based export documentation and provide electronic tracking.
The use of refrigerator trucks, refrigerator cars, reefer ships, reefer containers, and refrigerated warehouses is common.
Shipment in insulated shipping containers or other specialised packaging.[6]
Temperature data loggers and RFID tags help monitor the temperature history of the truck, warehouse, etc. and the temperature history of the product being shipped.[7] They also can help determine the remaining shelf life.[8]
Documentation is critical. Each step of the custody chain needs to follow established protocols and to maintain proper records. Customs delays occur due to inaccurate or incomplete customs paperwork, so basic guidelines for creating a commercial invoice should be followed to ensure the proper verbiage, number of copies, and other details.
During the distribution process one should monitor that process until one builds a sufficient data set that clearly demonstrates the process is in compliance and in a state of control. Each time the process does not conform to the process, the event should be properly documented, investigated and corrected so that the temperature excursion do not occur on future shipments. Any anomaly is thus considered to be a Non Conformance and should be assigned as a trackable event. The event must be reported immediately when it is identified and it is the expectation of the FDA that all adverse events to documented and investigated. The investigation should be completed in a timely manner and must come to some form of a "root cause" and also some form of "corrective action". The system may potentially stay in a Validated state if the root cause identifies that a Standard Operating Procedure (SOP) was not followed or followed incorrectly. If however a SOP needs to be changed or modified, then the system must be re-validated to demonstrate that the change to the SOP maintains the integrity of the process/system. A Non-Conformance may also generate a Corrective Action Preventative Action (CAPA), again, a documented process to make corrective or preventative actions to SOP's and other documents.
Non Conformances and CAPA's are an essential part of the overall Quality System in the cGMP environment. Tracking and trending of these events will also allow businesses to monitor the overall "health" of the systems in place. Excessive Non Conformances can quickly identify areas of concern for management and allow for corrective actions to be takes. During regulatory inspections of quality systems, inspectors will frequently ask to review a list of all "open" Non Conformances" so that they can quickly assess how an organization is processing these events and ensuring they are dealt with in a timely manner.
Thus the process is continually evolving and correcting for anomalies that occur in the process. Eventually the process can evolve into periodic monitoring once sufficient data demonstrates that the process is in a state of control. Any anomaly that occurs once a process is in a state of control may result in the process being invalidated and not in control and could potentially result in product withdraw from the market to ensure patient safety. A formal product withdraw is only done when the quality, safety or efficacy of a product is questionable. A single anomaly would not necessarily require a product withdraw if there is sufficient stability data that demonstrates that excursion