Divergences and corrective and preventive measures (CAPA) are other potential inconsistencies. The discrepancies require both the CMO and the sponsor to understand the cause and effects of a QMS process or excursion. The primary responsibility for investigating cases must be clearly expressed in the quality agreement, as well as when and how a sponsor can participate in an investigation. Often, large pharmaceutical and biotechnology companies have formalized survey frameworks that must be applied to deviations, while the CMO can authorize alternative approaches. The ability to reconcile two different requirements is essential to avoid unnecessary disruptions downstream of the commercial supply chain. This is another example in which limiting the scope to commercial programs is a missed opportunity for the Agency. The big question is: Why should the Agency provide a guide that only deals with commercial manufacturing? The role of the order manufacturer has grown over the past decade and has expanded to everything from API design to clinical logistics and pharmacovigilance. Commercial manufacturing is the relationship with which the biopharmaceutical industry has the most practical experience and the content and application of the quality agreement are well understood between the owners and the CMO. It is strange that the FDA has chosen to limit the scope of the guidelines to the commercial component when the main challenges for the industry are before commercial manufacturing.
A reasonably detailed quality agreement can help avoid assumptions that lead to compliance errors. However, while a quality agreement defines the specific quality parameters of a project and the parties responsible for their implementation, the degree of detail varies depending on the stage of development of the project. At least a quality agreement should specify each party`s obligations and responsibilities in the following fundamentals mentioned in the guidelines: the FDA`s current position on quality agreements is outlined in the «Contract Manufacturing Arrangements for Drugs: Quality Agreements» guidelines published in 2016.