Introduction
The Annual Product Quality Review (APQR) is a critical quality management activity mandated by global regulatory authorities including the US FDA, EU GMP (Annex 15 & 16), WHO, and ICH Q10. The purpose of the APQR is to systematically evaluate the consistency and quality of each marketed product, ensuring that manufacturing processes remain in a state of control, and that opportunities for continuous improvement are identified and implemented.
The APQR encompasses a comprehensive review of a wide range of product- and process-related data, including but not limited to:
- Batch production and quality control records
- Deviations, CAPAs, and change controls
- Stability studies and trends
- Complaints and returns
- Validation and qualification status
- Equipment and facility performance
- Regulatory updates and market feedback
However, when APQRs are incomplete, delayed, inaccurate, or poorly managed, they pose significant risks to product quality, regulatory compliance, and patient safety. The consequences of ineffective APQRs include:
- Missed trends in product quality or process performance
- Undetected deviations or recurring issues
- Non-compliance with GMP and inspection readiness standards
- Delayed identification of critical product risks
- Regulatory observations or enforcement actions
This risk assessment is conducted to evaluate the potential hazards associated with ineffective or improperly conducted APQRs. Using systematic tools such as 6M analysis (Man, Machine, Method, Material, Measurement, Milieu) and FMEA (Failure Modes and Effects Analysis), the assessment will:
- Identify common failure modes in APQR preparation, review, and approval
- Evaluate gaps in data collection, review processes, and documentation
- Assess risks from inadequate cross-functional involvement or training
- Determine the impact of missing or incorrect conclusions in APQR reports
- Recommend mitigation strategies such as automation tools, enhanced QA oversight, SOP revision, and staff training