A Guide to Good Distribution Practice (GDP)

Why is Good Distribution Practice Important?

Good distribution practice is important because it greatly affects public health. Any mistake in distribution can cause shortages, delays, and even the introduction of falsified medicines into the market.

Another reason why GDP is important in pharma is that it aids in product traceability, which can be a huge factor during official investigations of quality issues or incidents involving pharmaceutical products.

Overall, following good distribution practices protects wholesale distributors from situations that would not only damage their reputation in the industry but also harm the general public and lead to a huge loss in customers.

Who Needs GDP Certification?

According to the European Medicines Agency, all wholesale distributors of medicines in the European Economic Area (EEA) need GDP certification. Similarly in the UK, anyone that intends to sell or supply medicines to someone other than the end-user needs GDP certification.

In the European Union (EU), a GDP certificate is issued by the competent authority when the inspection has officially ended or 90 days since the last day of the inspection, provided that nearly all areas are GDP compliant. 

Good distribution practice in the UK is regulated by the Medicines and Healthcare products Regulatory Agency (MHRA). Unlike in the EU, the GDP certificate is only given when the MHRA inspector accepts the distributor’s response to the post-inspection letter.

GDP Guidelines or Principles of Good Distribution Practice

The following GDP guidelines are based on the World Health Organization (WHO) Good Distribution Practices for Pharmaceutical Products and the European Commission (EC) Guidelines on Good Distribution Practice of Medicinal Products for Human Use:

Quality System/Quality Management

A quality system should have the organizational structure, procedures, processes, resources, and actions needed to demonstrate that the distributor meets quality requirements. Quality management or the quality system must include a documented quality policy as well as authorized procurement and release procedures.

Wholesalers are also required to assess potential risks to the quality of products and follow quality risk management principles. Quality systems should be regularly reviewed and revised according to the recommendations of the risk assessments conducted.

Personnel

Management must appoint a responsible person whose duties include all the activities necessary for GDP compliance, such as implementing and maintaining the quality system.

The responsible person (also known as the qualified or designated person) is tasked with overseeing the organization’s GDP training programme. Initial and refresher GDP training is required for all personnel involved in distribution and should cover the following topics:

• product security
• aspects of product identification
• detection of falsified medicines
• avoidance of counterfeits entering the supply chain

The distributor must keep a record of all GDP training and routinely evaluate its effectiveness in promoting good distribution practices throughout the organization.

Supplier & Customer Qualification

Wholesalers need to check if a potential supplier has a wholesale distribution authorisation or a wholesale dealer licence before selecting them. Due diligence checks have to be performed and include observations on the following:

• the reputation or reliability of the supplier
• the likelihood that the pharmaceutical product offered is falsified
• the quantity of the pharmaceutical product offered, especially if typically it is only available in smaller quantities
• out-of-range prices

Additionally, wholesalers should only accept orders from customers with wholesale distribution authorisations, wholesale dealer licences, or are authorised to supply medicines to the public.

Storage

In general, warehouses should be clean, dry, and free from vermin. The temperature and humidity levels in storage areas should be within acceptable ranges. As much as possible, products must be kept off the floor and away from direct sunlight. There should be separate storage areas for the following:

• returned products 
• broken or damaged products
• recalled products
• suspected counterfeits
• hazardous products

Distributors also need to establish precautions against unauthorized access to the premises and prohibit food, drink, smoking material, and personal medication from storage areas. Additionally, they must ensure that warehouses have adequate cleaning and pest control programmes.

Though the First Expired First Out (FEFO) principle is recommended, exceptions to the principle are allowed as long as they are documented and no expired stock is distributed.

Warehouse managers need to conduct regular stock inventories, comparing the actual and recorded stocks. Any stock discrepancies or irregularities should be documented and investigated.

Transportation

Before dispatch, the wholesaler must first confirm that the delivery order is valid or that there is a documented material replenishment plan for the customer. After confirmation, the medicines are to be placed in a shipping container with a label that describes the handling and storage requirements and precautions, as well as the contents of the container and its source.

Once labeled, the shipping container can be loaded onto the vehicle at the appropriate time, according to the delivery schedule. It is important to remember that the quality, integrity, and security of the medicines during transit is still the responsibility of the wholesaler. 

Therefore, the wholesaler must establish measures and protocols which ensure the following:

• medicines are not damaged or contaminated while in transit
• required storage conditions are maintained throughout transit
• vehicles and medicines within those vehicles are protected against theft

If a deviation from any of the above occurs during transportation, the vehicle operator must report it to the wholesaler and to the intended recipient.

Documentation

Documentation should be sufficient enough to enable complete traceability of medicinal products across distribution channels. All parties involved have to be readily identifiable. Here are the requirements for documentation concerning the distribution of medicinal products:

• Clearly stated title, nature, and purpose
• Dated and approved by an authorised person
• Not changed without the necessary authorisation

All documents and records (such as that for dispatch and receipt) must be kept for 7 years, unless otherwise stated by the national or regional authority.

Complaints, Returns, Recalls

Complaints are to be divided into two categories: (1) those relating to the quality of the product and (2) those relating to its distribution. For quality complaints, the wholesaler is required to immediately inform the manufacturer or manufacturing authorisation holder. For distribution complaints, the wholesaler must conduct a thorough investigation to identify what’s causing the issue mentioned in the complaint.

For returns, the wholesaler has to perform an assessment that takes into consideration the following before adding the product back into saleable stock:

• nature of the returned product
• any special storage conditions required
• condition of the returned product
• its history and time elapsed since issue

However, if the returned product was a stolen product, it cannot be added back into saleable stock.

In the event of a recall, the wholesaler needs to inform the following supply chain stakeholders:

• manufacturer or marketing authorisation holder
• regulatory authorities in the country or region of the wholesaler
• customers and authorities of countries to which the products may have been distributed

The wholesaler must also record the progress of the recall and issue a final report that includes reconciliation between delivered and recovered quantities of products.

Falsified Medicines/Counterfeit Pharmaceutical Products

The distributor has to immediately notify the competent authority and the marketing authorisation holder upon identifying or suspecting a medicinal product to be falsified. The sale and distribution of suspected counterfeit medicines should be suspended. These products are to be stored separately from other products and labeled as falsified and not for sale. 

When it has been confirmed that the pharmaceutical product is a counterfeit, a formal decision must be made regarding its disposal. The distributor is required to take steps to ensure that counterfeits do not re-enter the supply chain or end up together with saleable stock.

Self-Inspections

A key requirement of good distribution practice is a self-inspection programme. The scope of self-inspections can vary. The wholesaler may decide that a comprehensive self-inspection performed less often is better than smaller, more specific self-inspections performed regularly. However, regardless of the scope, each self-inspection should:

• be performed in an impartial and detailed manner; and 
• be completed by a designated competent company personnel.

The results of each self-inspection must be recorded in a report that notes the observations made during the inspection. Any form of non-compliance, deficiency, or irregularity must be investigated and their root cause/s identified. The wholesaler also needs to establish, document, and follow-up on corrective and preventive actions (CAPA).

Make Sure Everyone Complies with Good Distribution Practice

Following GDP guidelines can be challenging for wholesale dealers since distribution is a very long process and involves a lot of people. Checking if each person in every stage of the process is complying with good distribution practice can be a bit of a headache. So, how can wholesale dealers get everyone on the same page when it comes to GDP?

Wholesale dealers can try SafetyCulture (formerly iAuditor), a mobile compliance tool that puts the resources needed to follow good distribution practices in everyone’s hands. SafetyCulture features that could help you promote and enforce GDP compliance:

• Complete GDP audit checklists with a few taps and capture photos as evidence of compliance.
• If anyone in your organization spots an issue with the product (signs of falsification, missing documentation, or defects), you can choose to be notified immediately so that you can handle the situation as soon as possible.

SafetyCulture for Good Distribution Practice