Good manufacturing practices guide for natural health products (GUI-0158): NHP GMP guidance, section 51

Quality assurance (section 51)

Section 51
  1. Every manufacturer, packager, labeller, importer and distributor shall
    1. have a quality assurance person who
      1. is responsible for assuring the quality of the natural health product before it is made available for sale, and
      2. has training, experience and technical knowledge relating to the activity conducted and the requirements of this Part; and
    2. investigate and record every complaint received in respect of the quality of the natural health product and, if necessary, take corrective action.
  2. Every natural health product shall be manufactured, packaged and labelled using only material that, prior to its use in the activity, has been approved for that use by a quality assurance person.
  3. Every natural health product shall be manufactured, packaged, labelled and stored using methods and procedures that, prior to their implementation, have been approved by a quality assurance person.
  4. Every lot or batch of a natural health product shall be approved by a quality assurance person before it is made available for sale.
  5. Every natural health product that is sold and subsequently returned to its manufacturer, packager, labeller, importer or distributor shall be approved by a quality assurance person before that natural health product is made available for further sale.

Intent

QA is the area of GMP concerned with sampling, specifications, testing, documentation and release procedures. The QAP is the person who maintains your quality system and assures that products are suitable for sale.

This regulation ensures that:

Manufacturer, packager, labeller, importer, distributor requirements

A comprehensive quality system will help you properly control manufacturing, packaging, labelling, storing, testing and distributing an NHP.

Ensure your quality system is maintained by a quality unit which is independent from where potential or perceived conflicts of interests may arise:

A quality unit fulfills both QA and QC responsibilities. Depending on the size and structure of your organization, this can be in the form of:

Note: For small companies, the senior official or business owner may be the most qualified to implement and run the quality system. In this case, you should have either:

  • controls in place that are robust, efficient and well-documented to ensure that only products that meet their specifications are released for sale or
  • a third-party QAP that has these controls in place

You should have a written job description for the QAP to ensure the individual makes decisions related to GMP requirements independently.

Support your QAP with a QA team to maintain an efficient oversight throughout your operations. This could be due to the size of your company, its business hours or when the extent of the documentation requiring review becomes difficult to manage due to your company's growth.

To maintain an efficient quality system, your QAP will put in place, manage and run various quality system components.

To help you comply with the requirements in section 51 of the regulations, these components are presented as quality subsystems in this guide. We have also provided detailed information on each of the components. You do not have to organize your quality system along these specific quality subsystems but should make sure that those that apply to you are in place.

The components of an efficient quality system include:

Quality assurance person training, experience and technical knowledge

Every manufacturer, packager, labeller, importer and distributor must have a QAP. This person is responsible for assuring the quality of an NHP before it's made available for sale. Your QAP must have the training, experience and technical knowledge of the buildings, equipment, procedures and practices used to conduct each activity outlined in the regulations.

A qualified QAP has appropriate and sufficient training, experience and technical knowledge:

You must have evidence that your QAP is qualified.

Refer also to the personnel section for additional guidance on the QAP.

Quality management system

The QAP, with the support of their team:

The QAP also:

Evaluate returned products for defects that could lead to changes being made to your company's processes. Product returns can be caused by quality, manufacturing, packaging or labelling problems, which must be fixed.

Deviations

A deviation is the departure from an established or approved procedure, process, work instruction or form, or an accepted standard. An example would be an OOS result.

Some deviations are not planned (for example, when a manufacturing process is not followed because equipment failed during production).

Some deviations are planned (for example, when a piece of equipment not listed in the master production documents is used instead).

Investigating deviations under your quality system shows that your company:

Note that deviations are not always a negative occurrence.

As well as identifying the deviation as planned or unplanned, the QAP should rate its scope and severity (critical, major or minor) by evaluating its potential impact on the following:

Types of deviations:

Document, investigate and resolve any deviation from established procedures and standards as quickly as possible. Major and critical deviations may lead to:

To investigate deviations efficiently, we suggest defining a reasonable timeline for this based on the deviation rating. For example, investigations into critical, major and minor deviations could be completed within 10, 20 and 30 working days, respectively. You should not release a product on the market before you confirm that the deviation did not affect the product's safety, efficacy or quality.

Out-of-specifications

An OOS is a specific type of deviation. An OOS occurs when:

Section 44 of the regulations states that every NHP available for sale must comply with the specifications submitted during the product licensing process. Thus, releasing OOS products for sale without following an approved written procedure (SOP) for investigating OOS results and correcting the root cause is a serious GMP error and a non-compliance with the regulations.

When investigating an OOS, the QAP, with the support of their team, is responsible for:

As the QAP, ensure that OOS test results are investigated in accordance with a written procedure (SOP). This procedure should include the following aspects:

OOS results may require you to implement CAPA. Refer also to the CAPA process section of this guide.

Remember that repeated testing or sampling until a passing result is obtained to invalidate the OOS is not an acceptable practice. This is commonly referred to as “testing into compliance”.

Laboratory control system

A laboratory control system may differ greatly from one organization to another. It will depend on how a manufacturer, packager or importer decides to test (analyze) their material or product to ensure specifications are met prior to sale. Companies may completely outsource product testing or do it entirely in-house. Some may do a limited subset of simple analysis (such as brix, density or pH) and outsource the rest.

Testing is fundamentally linked to sections 44 and 51 of the regulations. Although testing is not a licensable activity under Part 2 of the regulations, manufacturers, packagers and importers must have a laboratory control system. The breadth and depth of this system will depend on whether you have an in-house laboratory or use a third-party laboratory.

Note: The following pharmacopoeias and international standards are included in Schedule B to the Food and Drugs Act (always reference the most current version):

  • European Pharmacopoeia (Ph.Eur.)
  • Pharmacopée française (Ph.F.)
  • Pharmacopoeia Internationalis (Ph.I.)
  • The British Pharmacopoeia (B.P.)
  • The Canadian Formulary (C.F.)
  • The National Formulary (N.F.)
  • The Pharmaceutical Codex: Principles and Practices of Pharmaceuticals
  • The United States Pharmacopoeia (U.S.P.)

Third-party laboratory testing

If your company outsources testing to a third party, your QAP must still be involved in maintaining the laboratory control system. The QAP, with the support of their team, ensures that:

Regardless of who conducts the testing, the Canadian manufacturer or importer must make sure that:

In-house laboratory testing

In addition to what is needed for third-party laboratory controls, the role of the QAP expands when testing is done in-house. The QAP is typically supported by personnel who have the appropriate scientific background to do testing.

The QAP, with the support of their team, ensures that:

Note: Only qualitative methods (as opposed to enumerative or quantitative methods) for specific microorganisms are acceptable when determining their presence or absence.

Importation control system

The importer is the final party responsible for products imported into Canada and thus plays a critical role in ensuring that the products are safe, effective and of high quality. Part of this role is monitoring foreign manufacturers, packagers and labellers to ensure that imported NHPs meet appropriate standards and have been manufactured in a GMP environment. Refer to the operations section for more information.

When you import products, the QAP, with the support of their team:

Risk management system

Risk management involves assessing, controlling, communicating and reviewing risks that could affect the quality of an NHP across its lifecycle. A quality risk management process can help a company comply with GMP requirements. Refer to the quality risk management section for more information.

A risk management system for quality involves CC and CAPA. It also includes internal audits (self-inspections) to proactively identify potential issues.

For examples of quality risk management processes and applications, consult the ICH's guideline, adopted by Health Canada:

Although NHPs are not within the scope of ICH guidelines, such references are helpful to the NHP industry and other stakeholders. The guidelines may help you gain a better understanding of GMP concepts and processes that also apply to NHPs.

Change control

A CC process will help you:

Establish and implement written procedures (SOPs) to support your CC process. When implementing a CC process, the QAP, with the support of their team:

Corrective and preventive actions

CAPA are taken to eliminate the cause of a detected non-conformity or undesirable situation. Always have in place a process for CAPA so that personnel can correct an undesired, unacceptable or improper issue or practice. This will also help to prevent it from happening again. An efficient CAPA process supports a company's ongoing and long-term GMP and QA standards.

Key terms related to CAPA:

The key steps of a strong CAPA process are:

  1. Identify a GMP deficiency or product issue
  2. Document and record
  3. Assemble a team of subject matter experts to review and investigate
  4. Use immediate correction measures to contain the problem
  5. Identify the root cause
  6. Evaluate the impact
  7. Implement a CAPA plan
  8. Monitor the effectiveness of the plan
  9. Close the CAPA with QAP approval

Refer to the CAPA process section of this guide for more information.

The following events may trigger the need to initiate a CAPA process:

Your QAP is responsible for establishing, monitoring and maintaining a CAPA process, which includes:

Your CAPA process may lead you to identify or consider that the issue may affect other products or processes. Your CAPA investigation should include those products or processes.

Importers are responsible for the products they import into Canada. Also note:

When product-related issues are identified, the importer must develop and implement a strong CAPA plan. Although this plan may leverage the foreign manufacturing, packaging or labelling sites, the importer must ensure that processes and controls are in place to prevent the event from occurring again.

You should do periodic self-inspections to monitor GMP and proactively correct issues. During the self-inspection, ensure to cover all GMP that apply to your activities. For more information, consult the self-inspection chapter in the PIC/S's Guide to good manufacturing practice for medicinal products, part I.

GMP evidence

Your QAP must be qualified. You must have evidence to support this and the responsibilities of this position. Examples of evidence include:

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2025-09-04