Responsibility resting on a single set of shoulders.
An owner-led, mid-sized CDMO focused on aseptic filling lost its Head of Quality Management to a competitor at short notice. The timing could hardly have been worse. Several customer audits were running in parallel while a demanding tech transfer was due. In a market segment where sterile fill-finish capacity is structurally scarce and outsourcing to contract manufacturers is the fastest-growing area of demand, this is precisely the moment when a CDMO has to prove its reliability to its clients.
The real edge of the situation, however, was not in the open audit but in the statics of responsibility. Batch release rested on the single remaining Qualified Person. Under § 19 of the German Medicines Act (AMG), it is exclusively the Qualified Person who certifies every batch before it is placed on the market. Without personnel redundancy, this legally mandatory function became a classic single point of failure, and that under the tightened inspection standard of the fully revised EU GMP Annex 1 in force since 25 August 2023. For us as a specialised pharma recruitment firm it was clear that this was not about backfilling a role, but about closing a regulatory availability gap.