Interpretation of requirements reflected in the Aide Memoire For the assessment of Procurement Agencies Based on the Model Quality Assurance System1 INSPECTION OF A PROCUREMENT AGENCY 1. MQAS. WHO TRS 937 Assessment Tool: Procurement Agency. Version 1. 2013. Page 1 Table of contents 1. 2. 3. 4. 5. 6. Document history Introduction Purpose Scope Interpretation notes Revision history 1. Document history Action Date Preparation of first draft May 2013 2. Introduction This document reflects common interpretation of the recommendations as listed in the World Health Organization (WHO) Model Quality Assurance System for Procurement Agencies (MQAS) and the Aide Memoire used to assess Procurement Agencies. (This harmonized tool (aide memoire) and interpretation document were developed by a working group consisting of representatives from the following organizations: QUAMED, PFSCM, UNICEF, MSF, IDA, Crown Agents, GDF, MSH, UNION, UNOPS, USAID, ICRC and CHMP). 3. Purpose The interpretation document was developed by the working group with the objective to further clarify the expectation of what has to be done to satisfy (or what is meant by) the recommendation in the MQAS and aide memoire, to ensure compliance with the MQAS. The document only reflects on some important aspects in these documents referred to and does not address all the recommendations. 4. Scope The MQAS and aide memoir consist of 6 Modules: Module I General requirements for Procurement Agencies Module II Prequalification Module III Purchasing Module IV Receiving and storage Module V Distribution Module VI Re-assessment 5. Interpretation document This document attempts to clarify some of the recommendations; or to clarify what is expected from a PA to achieve the objective of the recommendation in the MQAS. Assessment Tool: Procurement Agency. Version 1. 2013. Page 2 Module I: General requirements for Procurement Agencies (PA) It is expected that a PA should have an infrastructure that supports its activities. That means having suitable premises; working equipment and furniture; and the necessary transport (self or contracted) to perform its functions appropriately. The PA must be operating within the provisions of the national legislation (e.g. licensed). The organization chart, job descriptions, training records should be current, have sufficient detail, and should be signed and dated. There should be enough space for orderly storage of documents and products that will prevent loss of data, prevent mix ups, support cleaning and operations carried out. The environmental conditions (temperature and relative humidity) should be controlled as required on the labels of the products. Vehicles should be available and in good conditions if the PA is responsible for delivery / transport of products The number of people employed should be sufficient to perform the activities claimed. The individuals should have qualifications, training and experience in the relevant fields that they are working in. Quality assurance, prequalification and purchasing personnel should be independent of one another to ensure that there is no conflict of interest. There should be no conflict of interest meaning that any employee should not have any connection, association, shares or other with a company supplying products to the PA. The code of conduct prescribes behavior of employees should comply with including ethical and professional conduct. No person should divulge any confidential information relating to any company or supplier to any other party Where computer systems are used for purchasing, stock control, data management, systems should be followed to ensure authorized access, data integrity, and maintenance. Operators should be trained according to SOPs and records should be available to show the assessment outcome after training The PA should be in good financial standing and must be using legitimate banking procedures and facilities, with appropriate records in place for accounts, signatures, and financial statements indicating debits and credits All PA policies, guidelines, SOPs should be available in paper or electronic copy and accurately reflect the quality systems. This includes a quality manual, risk management, SOPs, and site layouts. Where necessary, documents (e.g. SOPs, layouts, job descriptions) should be reviewed for accuracy, signed and dated by authorized personnel, and be current. Contracts (agreements) must be signed and dated where activities are delegated to other parties Relevant records of activities and transactions should be maintained in storage areas (access controlled, and under appropriate storage conditions to prevent deterioration) for a period that complies with national legislation Assessment Tool: Procurement Agency. Version 1. 2013. Page 3 Module II: Prequalification When a PA performs prequalification, policies and procedures must be available for the activities such as products assessment and site inspections Personnel doing dossier assessments (evaluating data and information) and site inspections (assessing compliance with GMP) should have qualifications and experience in this, follow SOPs and remain within the scope of their job descriptions. Assessors of dossiers should communicate points and information they observe from the dossiers to the inspectors to assist them when they inspect sites, to verify data and investigate discrepancies. The assessors and inspectors should not be responsible for purchasing Module III: Purchasing Procurement should be done with the aim of purchasing effective, quality assured products, and not be focused on price alone. The term “procurement” in this Module relates specifically to the purchase of health sector goods from manufacturers or suppliers. Purchasing should be from reliable suppliers and transparent purchasing practices should be followed. Products should be selected from the list/catalog of products (INN) and meet their specifications. Quantification of needs must be accurate and quantities purchased based on reliable estimates Once products are supplied, the PA should on a risk based approach – sample products for testing purposes. Detailed procedures should be implemented for handling any out of specification results. Other monitoring systems should include investigation of complaints, monitoring of adverse events, reassessment of products and sites at defined intervals, monitoring of contracts and costs. Donations should only be accepted if the principles are met as described in the WHO Guideline for Donations Module IV: Receiving and storage Detailed SOPs should be followed for receiving and storage of products. Containers should be checked and cleaned before taken for storage. Products have to meet their specifications. There should be sufficient space for orderly storage of products according to their storage conditions specified on the labels; and allowing cleaning of the areas and ventilation. Stock should be rotated to ensure that earlier expiry stocks are issued first. Rodent and pest control should be in place. Environmental conditions should be monitored e.g. with a minimum maximum thermometer at regular intervals; or with other suitable devices that will give results of the conditions over a period of time. Assessment Tool: Procurement Agency. Version 1. 2013. Page 4 An appropriate system (e.g. electronic) for stock control should be used for receiving , dispatch, reconciliation, obsolete materials, recalled products, returned goods, FEFO and waste Records should be kept showing traceability of all batches of product Module V: Distribution The PA (or contracted party) should have a well-managed distribution system meeting the objectives of ensuring constant supply of quality medicines. Packaging and transport of products must be controlled to ensure that these are not damaged during transit, and that storage conditions are met (e.g. including temperature monitors when needed). FMEA can be used in risk assessment exercises when temperature excursions are noted. Products to be transported in a cold chain need to be packed in containers with precautions and materials to assist in maintaining the storage conditions. Products can only be supplied to those who are legally allowed to posses such products Module VI: Re-assessment Quality of products and services should be continuously monitored. This process includes reassessment of product data and information, as well as site inspections. If at any time, the PA establishes that product(s) no longer meet their specifications, procedures should be implemented to ensure that appropriate action is taken (and may include suspension of products and suppliers; or withdrawal) 6. Revision history Date Version number Reasons for revision May 2013 1.2013 Original Assessment Tool: Procurement Agency. Version 1. 2013. Page 5