06/04/2026
API manufacturers operate under their own GMP standard: ICH Q7. And it has a specific audit finding that comes up more than any other.
ICH Q7 Section 2.1 requires the quality unit to be independent of production, with authority to reject batches and override production decisions without escalating to manufacturing management. An org chart where Quality reports to the same VP as Manufacturing does not satisfy that requirement. Auditors test this directly by asking the quality unit manager: "Tell me about the last time your team rejected a batch against production's recommendation."
Three sections reveal the most in an ICH Q7 audit:
Section 2, Quality Management: is the quality unit structurally independent?
Section 6.7, Batch Record Review: are complete records reviewed before release?
Section 13, Change Control: does scope apply consistently across every step in a multi-step synthesis route?
If your team manufactures APIs, qualifies API suppliers, or is preparing for a regulatory agency audit, ICH Q7 Chapter 2 is where to start.
Cloudtheapp's Supplier Qualification module helps manufacturers and sponsors track API supplier audit status, GMP certifications, and change notifications in one connected quality system.
See how it works: cloudtheapp.com/demo