Sunday 23 June 2013

A Call for Croatian Translators



This week saw the EC advertise for Croatian translators via Twitter.  Now you may be thinking how this relates to a QP training blog?




On the 1st of July this year Croatia will become the 28th member of the European Union.    As a QP you are expected to have a 'comprehensive knowledge of all EU and national legislation relating to the manufacture, storage & supply of medicines...' as defined by the QP study guide.  In order to have this knowledge you first need to know which countries are legally bound to this legislation and which countries are likely to join in the near future.

The EC Europa website gives a useful overview of the status of the EU member states and importantly those countries that are in the process of applying for membership.  In order to get to the first step in the process the country has to meet strict conditions for membership including incorporation of the 35 policy chapters of the EU, including chapter 28 (consumer & health protection) that covers EU legislation on medicines.

Potential countries are grouped into 3 categories depending on their current status.  The first category is for Potential Candidates and are invited to formally begin application proceedings only when they are ready.  As countries progress through their application they then become a Candidate Country and finally an Acceding Country once EU membership terms have been agreed.

Current Status of EU enlargement:

Category
Country
Acceding Country
Croatia (Entry 1st July 2013)
Candidate Countries
Macedonia, Iceland, Montenegro, Serbia, Turkey
Potential Candidates
Albania, Bosnia, Kosovo


Montenegro and Iceland are the 2 candidate countries where negotiations have been ongoing for a number of years.  These countries are the most likely to become acceding countries over the next few years. 

Relevance to the QP viva?

Having knowledge on the countries that are nearing EU membership (particularly the acceding countries) will help in your preparation for the common 'round the world' supply chain questions and scenarios.  These typically involve importation of APIs, intermediates or final products into the EU via a number of 3rd countries. 

Taking Croatia as an example, from 1st July 2013 it goes from a 3rd country to a Member State.  Therefore if you viva is coming up soon there is a high chance that the assessors will include Croatia in their supply chain scenario.  If you fail to recognise that Croatia is a 3rd country before 1st July 2013 then it is highly likely that your answers regarding importation will be incorrect and will obviously not go down well with the assessors. Having an awareness of upcoming additions to the EU shows the assessors that you understand the structure of the EU & have an appreciation of how the continuously evolving landscape within Europe affects your role as a QP.

The table below highlights some factors relevant to QPs regarding the inclusion of Croatia into the EU:



Croatia (pre 1st July)
Croatia (post 1st July)
Legal Status
3rd Country
Member State
Finished product import Croatia into UK

Testing on import required

No testing on import required
API import Croatia into UK
Written confirmation would have been required
 No restriction
QC Testing location
Importation Testing not permitted
Importation testing allowed
Retention Sample
Cannot be stored here
Can be stored here
IMP comparator sourcing
Unlikely to be sourced (equivalent EU GMP to be determined)
Likely to be sourced (EU GMP incorporated into local law)
  

Summary

As I've mentioned previously it's important to maintain up-to-date regarding the relevant legislative & GMP updates in preparation for your viva and throughout your QP career.  I would also recommend to include the structure of the EU (including EEA, EFTA etc) as well as upcoming changes as part of your update strategy leading up to your viva.  Including this RSS feed into your updates folder is highly recommended.

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