创建以过程管控为核心的中药质量控制技术体系

该文首先简述中药质量控制技术现状、瓶颈问题及严峻的挑战,提出应改变以事后检验为主要手段而不重视过程管控的药品监管现象,扭转业界忽视发展制药过程管控技术的局面,重构中药产品质量控制技术体系;通过建立以制药过程管控为核心的中药质量控制技术和监管体系,从根本上解决质量控制技术落后、质量风险管控措施不力、产品质量声誉不高等中药行业重大现实问题,从而突破中成药产品质量可控性差等难关。围绕中药质量控制技术领域中的难点问题和薄弱环节,提议尽快构建具有中国原创特色的中药CMC(chemistry,manufacturing and controls)技术规则并推动其得到国际认可,同时设计了以临床疗效为导向、制造方式为主轴、过程控制为重点的中药CMC技术架构。根据中医药临床特色及中成药生产特点,建议将药物分析学与中药化学、中药药理学、制药工程学、控制工程学、管理工程学等学科相结合,创立中药质量控制工程学。进而,提出中药质量控制工程理论模型及数字制药工程方法学,阐述了显著提升中药标准、实现中药国际化战略目标的技术路径。

A strategy of constructing the technological system for quality control of Chinese medicine based on process control and management

The current situation, bottleneck problems and severe challenges in quality control technology of Chinese Medicine (CM) are briefly described. It is presented to change the phenomenon related to the post-test as the main means and contempt for process control in drug regulation, reverse the situation of neglecting the development of process control and management technology for pharmaceutical manufacture and reconstruct the technological system for quality control of CM products. The regulation and technology system based on process control and management for controlling CM quality should be established to solve weighty realistic problems of CM industry from the root causes, including backwardness of quality control technology, weakness of quality risk control measures, poor reputation of product quality and so on. By this way, the obstacles from poor controllability of CM product quality could be broken. Concentrating on those difficult problems and weak links in the technical field of CM quality control, it is proposed to build CMC (Chemistry, Manufacturing and Controls) regulation for CM products with Chinese characteristics and promote the regulation international recognition as soon as possible. The CMC technical framework, which is clinical efficacy-oriented, manufacturing manner-centered and process control-focused, was designed. To address the clinical characteristics of traditional Chinese medicine (TCM) and the production feature of CM manufacture, it is suggested to establish quality control engineering for CM manufacturing by integrating pharmaceutical analysis, TCM chemistry, TCM pharmacology, pharmaceutical engineering, control engineering, management engineering and other disciplines. Further, a theoretical model of quality control engineering for CM manufacturing and the methodology of digital pharmaceutical engineering are proposed. A technology pathway for promoting CM standard and realizing the strategic goal of CM internationalization is elaborated.