Specialist track · Regulatory and Quality Specialization

GMP Thinking for Small Makers

What does good manufacturing practice mean at a small scale? Run a gap check based on ISO 22716's topics, fix the biggest risks and avoid false claims.

In short

Good manufacturing practice means organizing your work so each batch is made the same way, from known materials, in clean conditions, by people who know what to do, with records to show it. For a small maker, this can be modest, though it can't be absent if you sell in a market that requires it. In the EU, Article 8 of Regulation 1223/2009 requires GMP, and following the relevant harmonized standard, ISO 22716, gives a presumption of compliance. The GMP guide gives an overview. Here you will apply it to your own room.

What you will learn

  • Explain the logic behind GMP
  • Run a gap check against ISO 22716's topics
  • Choose proportionate improvements, and describe them accurately

Before this lesson: Deviations and Corrective Action

The logic

GMP asks you to prevent four main problems: mix-ups, contamination, errors and undocumented change. Each section of a standard largely addresses one of those. If you understand these, its rules start to make sense.

A gap check

Topics broadly following ISO 22716's coverage. Written as our questions, and not as the text of the paid standard. Buy it if you need the full requirements.
TopicA small maker's questionEvidence you might have
PersonnelWho does what, and are they trained for it?Training notes
PremisesIs the space separate from home life, clean and ordered?Floor plan, cleaning log
EquipmentAre scales checked? Vessels clean?Calibration log
Raw materials and packagingGoods-in checked, labeled, stored, rotated?Goods-in forms
ProductionIs there a master record, with lots noted at weighing?Batch records
Finished productsIs there a release decision, and is stock controlled?Release records
Quality controlWhich tests, on what basis?Specification
Out-of-specificationWhat happens with a failure?Deviation records
WasteHow is chemical waste handled?Procedure, local rules
SubcontractingAre others' responsibilities written down?Agreements
DeviationsRecorded and reviewed?Log
Complaints and recallsCan you act quickly?Log, drill
Change controlAre changes reviewed before use?Change log
Internal auditDo you check that you follow your rules?Annual review
DocumentationIs everything current, findable and kept?Index

Prioritizing

Score each gap for how likely it is, and how bad it would be. Fix the worst first.

A sample ranking, with invented scores from 1 to 5
GapLikelihoodSeverityScoreAction
Lookalike bottles, no code check4520Add a check to the record; relabel
Scale never checked3412Monthly test with a known weight
Cleaning not logged326Simple log

Small-scale realities

  • Home workspaces. Some jurisdictions have specific rules on domestic production, and insurers may too. Check them. Keep materials away from food, children and pets.
  • Working alone. You can't double-check yourself in the moment. Use barcode-like checks, weigh-and-tick records and a delay before sign-off.
  • Procedures. Short ones, as described in lab SOPs, are better than long ones you won't read.
  • Contract manufacture. A manufacturer's GMP doesn't remove yours as a brand. Agree who does what.
  • US and other markets. MoCRA requires FDA to establish GMP regulations, with exemptions for some small businesses. Check their status.

Describing it honestly

Honest wording on GMP
Avoid unless trueSay instead
ISO 22716 certifiedWe use ISO 22716 as a guide; we haven't been audited
GMP approvedOur procedures are described in our quality file
Made in a sterile labMade in a dedicated, cleaned workspace

Practical exercise: A GMP gap check

About 120 minutes · You will have: a gap table for your workspace, three prioritized actions and two written procedures

  1. Walk through your workspace with the gap table, recording evidence for each row.
  2. Score each gap, and pick your top three.
  3. Write two one-page procedures: one for weighing a batch, and one for goods-in or cleaning.
  4. Test a procedure by having someone follow it.
  5. Set a date to review the table in three months.
  6. Find out what your market requires, and note the source and date. Mark what you'd ask a qualified person.

You have done this well if your gaps are specific, your first fixes target your largest risks, and nothing you say about yourself overstates what's been done.

Common mistakes

  • Writing procedures you don't follow. That's worse than none.
  • Treating GMP as paperwork. The records serve the batch.
  • Claiming certification. Only if you hold it.

Key terms

Good manufacturing practice
An organized way of making products so that they are consistently produced and controlled to appropriate standards.

Knowledge check

1. What does the EU Cosmetics Regulation say on GMP?
Show the answer

Manufacture must comply with GMP, and following the relevant harmonized standards creates a presumption of compliance. See Article 8 of Regulation (EC) 1223/2009, and check how it applies to you.

2. You followed ISO 22716 as a guide, with no audit. What can you truthfully say?
Show the answer

We use ISO 22716 as a guide for our procedures. Only claim certification you hold and can show.

3. Which risk should you probably address first?
Show the answer

The one with the largest effect, such as mix-ups between bottles. Use your gap check, and work on what would most likely harm a product or a person.

Written and reviewed by the RUŌOD Lab team. This is general education, not legal, regulatory, medical or safety advice. Example dilutions and exercises are for learning, are not validated products, and have not been safety-assessed. Completing a lesson confers no qualification. How we check these lessons.