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Evolving Regulatory ParaphernaliaEvolving Regulatory Paraphernalia – Exciting opportunities
A.G. RaghuHead – Quality & Regulatory AffairsApotex Pharmachem India Pvt. LtdBangalore
USFDA
ICH Japan
How to overcome…
TGAEDQMMHRA
nalia
aphe
rn
APRsOOS/OOT
Para
DeviationQualifications
Change controls
Validations
20th century….
Traditionally the pharmaceutical industry isa highly regulated environment withlittl fl ibilit i hi h l t hlittle flexibility in which regulators havetaken the responsibility for product quality.
Beginning 21st century….
Vision to move to a new desired state….
“A maximally efficient, agile, flexiblepharmaceutical manufacturing sector thatreliably produces high quality drugproducts without extensive regulatoryoversight”oversight
Janet Woodcock, M.D.
Chief Commissioner of Operations, FDA
Starting point……
August 2002: FDA launched the initiative“Pharmaceutical Current Good ManufacturingPharmaceutical Current Good ManufacturingPractices (cGMP) for the 21st Century: A RiskBased Approach”
Designed to evaluate and improve theagency’s approach to reviews and inspectionsrelated to the manufacturing of human andanimal drugs and biologicsanimal drugs and biologics.
Next……Brussels July 2003 (ICH)
D l h i d h i lDevelop a harmonized pharmaceuticalquality system applicable across the lifecycleof the product emphasizing an integratedof the product emphasizing an integratedapproach to quality risk management andsciencescience.
USFDA/EU/TGA/J
Harmonization of inspections
USFDA/EU/TGA/Japan
Rationalization of international GMPinspectors
Mutual Recognition Agreements (MRA) org g ( )Memorendum of Understandings (MOU)between regulatory authorities
Integration of policy guidelines byregulators across the worldregulators across the world
Exchange of inspection reports amongregulatorsregulators
July 2003: An ICH vision
The Regulatory
For companies with :1. Good design and Quality Risk
Management
Quality Risk Management
The Regulatory Quality System control strategies
2. Good Risk Management strategies
3. Good Quality Systems
Management (Q9)
Quality by Design(Pharmaceutical
Development)Quality
Quality by Design Reduced regulatory
b dQ ySystems
Quality
y g(Q8) burden:
• Reduction of submissions on changes/variationsI ti f litExisting Existing GMPGMP’’ss Quality
Systems (Q10)
• Inspection of quality systems
New approaches…
ICH Q11: Development and manufacture of ICH Q11: Development and manufacture of drug substances Draft
USFDAGuidance for Industry ProcessValidation: General Principles andPractices
FDA Initiative: January 2007
Question based review (QbR) for Generic Drugs……g
Product quality and performance..‐ by effective designby effective design‐ Efficient manufacturing processes
Product specifications based on……‐ Mechanistic understanding of formulation and process factors impact on product performance
Ability of manufacturers to effect continuous improvement andcontinuous "real time" assurance of quality
Focus of regulators during Review & inspection
Process knowledge gained on variousStage of Product Life cycleScience based justificationRisk Based ApproachICH Q8/Q9/Q10 & Q11 (Draft)
Knowledge management during product lifecycle implementation
Process developmentProcess development….
Multivariate studies / InteractionUse of Statistical ToolsQuality Risk Management
Technology transfer
R&D Lab experimentsScale up challengesChallenges in process consistencyRisk based assessment
Routine Commercial production
P lid ti P fProcess validation – Process performancequalifications (PPQ)
Continued process verifications – Annualproduct quality review (APQR)product quality review (APQR)
Change ManagementChange Management
Increased focus on product and processunderstanding
Questions asked onQuestions asked on
Product designgCritical quality attributesCritical material attributesCritical process parametersLack of clear rationale behind setting specificationMi i l j ifi i lMinimal justifications on scale up process
Critical process parameters
Identified
Ranges are scientifically justified
Unidentified critical steps & process parametersmay be indicative of poorly controlledmanufacturing process High riskmanufacturing process – High risk
Higher assurance – Process is RobustgIncreased probability ofsuccessful scale up
Non-acceptance of advanced intermediates as starting material
Backward integrationorAssurance from vendor for supply of early stage raw materials
Vendor Selection
Commitment Consistent qualityConsistent supplySe ect o
QualificationAudit
pp yCGMP complianceData on requestChange intimation
Designing the process to achieve the parameters
Polymorphismy pParticle size distribution (PSD)Control of impurities in‐line with ICH Q3Ap QPotential Genotoxic impuritiesResidual solvent control in drug substanceResidual solvent control in drug substanceChirality of drug substance
Control of impurities
Tightening of total impurities based on the compendia..
Introduction of new impurities in the drug substancespecification
Process improvementsProcess improvements
Validation Impact – Analytical & Process
Stability impactStability impact
Etc.
Control of impurities
Process improvementsProcess improvements….
Challenge could be to modify the process toachieve the desired level or limit of the newlydd d i itadded impurity
Control of impurities
Validation Impact – Analytical validation
Need to revalidate the methodMethod consistency and validation even at Key startingstages alsoS ifi M h d f d i d d i l i i i Specific Methods for detecting degradational impuritiesand method capabilities at QL level Degradation at Stress conditions and establishing the massbalancebalance
Validation Impact – Process validation
Need to re validate the process Need to revalidate the process
Control of impurities
Stability impact
Stability batches may not comply to thelimit of the added impurity.
Retract the shelf life.Retract the shelf life.
Inorganic catalysts
Need to demonstrate the control of residualinorganic catalysts such as Palladium (Pd)inorganic catalysts such as Palladium (Pd) ,Rhodium (Rh), Cadmium (Cd), Chromium(Cr) etc in final drug substance using(Cr), etc. in final drug substance usingvalidated analytical method by advancedtechnique; ICP‐OES (Inductively coupledtechnique; ICP OES (Inductively coupledplasma – Optical emission spectroscopy).
Manufacturing
Justification on the overages in the formulation bydemonstrating a similar in Referenced Listed Drugdemonstrating a similar in Referenced Listed Drug(RLD)
Why this excipient and why is this quantity
Granulation end point is subjective. Steps to be taken if ap j psuitable granulation is not formed by allocated time ofmixing and its effects on Quality of final Product.
Particle size distribution and its impact on thedissolution profile, content uniformity and Bio‐availabilityavailability
Excipients
API Compatibility ‐ Justifications based onmechanistic understanding of chemical interactionof drug substances and excipients andof drug substances and excipients andmanufacturing processes.
Possibility of degradation of API in presence ofPossibility of degradation of API in presence ofexcipients.
Significant reactive excipient impurities such asHydrogen Peroxide, Formaldehyde, Formic acid.
Suitability of analytical method to identifydegradant impurities formed by excipientdegradant impurities formed by excipientinteraction with API.
Low drug excipient ratio leads to higher risk ofLow drug excipient ratio leads to higher risk ofreaction.
Container Closure System
Moisture permeation data for the proposed BlisterPack Impact on
‐ Product Quality / Aesthetics‐ Product Stability / DegradationP d t I t it‐ Product Integrity
Extractable and Leachable Studies for proposedExtractable and Leachable Studies for proposedstoppers
‐ Impact on Product Qualityp Q y‐ Relationship to formulations (pH etc.)
Container Closure System
Specific Attributes – impact on Product quality ‐ Studyresults
Solid Oral Product Package driven by Stability issues‐ Light Sensitivity‐ Light Sensitivity‐ Moisture Protection‐ Inert Atmosphere‐ Tablet Integrity
How to overcome these challenges
ICH Quality trio Q8, Q9, Q10 will providesolution
Significant benefitsSignificant benefits‐ Guidance in demonstrating processand product Knowledgeand product Knowledge‐Accelerate continuous improvement
Throughout the product life cycle
Product life cycle: ICH Q10•Drug substance development
Pharmaceutical Development
Drug substance development• Formulation development•Manufacture IMP• Delivery development•Manuf. process development•Scale up• Analytical method development
Technology Transfer
• Analytical method development• New product transfer• Transfer marketed product between & within Manuf. & Test sites
Validations • Equipment• Analytical method • Process • Cleaning validations
Commercial Manufacturing
•Acquisition & control material• Facilities provision• Utilities & Equipment provisionCommercial Manufacturing Utilities & Equipment provision• Production• QC & QA• Release•Storage & Distribution
Product Discontinuation•Retention of documents• Sample retention• Continued product assessment and reporting
Objectives - ICH Q10Achieves Product RealizationAchieves Product Realization“Delivery of products with the quality attributes appropriate to
Meet the needs of patientsHealth care professionalsHealth care professionalsRegulatory authorities ”
Establishes and Maintains a State of Control“ ff i i i d l f“..effective monitoring and control systems for processperformance and product quality ..”
Facilitate Continual Improvementp“..implement, appropriate product quality improvements, processimprovements, variability reduction, innovations andpharmaceutical quality system enhancements ..”
Enablers‐ Knowledge Management‐ Quality Risk Management
Objectives - ICH Q10Knowledge Management Knowledge Management
Product and process knowledge should bemanaged from development through theg f p gcommercial life of the product up to andincluding product discontinuation
Quality Risk Management
‐ Quality risk management is integral to anQ y g geffective pharmaceutical quality system
‐ Proactive approach to identifying, scientificallyevaluating and controlling potential risks toquality
Pharmaceutical DevelopmentQuality by Design (QbD)
The development approach should be adapted based on the complexity andspecificity of product and process
Critical Quality attributes (CQA)Critical Process parameters (CPPs)Quality Target Product Profile (QTPP)
The information developed to determine CQAs and CPPs will help to:
Develop control strategy; p gy;Ensure quality of the product throughout the product lifecycle; Increase product and process knowledge; Increase transparency and understanding for regulators and industry; Evaluate changesEvaluate changes.
Pharmaceutical Development
Control strategy
Initially implemented for Pilot scale batches redefinedInitially implemented for Pilot scale batches, redefined further in scale up and commercial lots
Acceptance criteriaAcceptance criteria
Analytical Methodology
Emphasis on process controlEmphasis on process control
The scientific justification of the proposed control strategy. gy
The scientific rationale for the studies conducted.
Technology Transfer
Management of scale up issues
Risk associated on scale up
C t l t t t iti t i kControl strategy to mitigate risk
Management of site change / Contract manufacturing (Regulatory impact)
P lid ti i d fi d th ll ti d l ti f d t f th
Process Validation
Process validation is defined as the collection and evaluation of data, from theprocess design stage through commercial production, which establishes scientificevidence that a process is capable of consistently delivering quality product.
The lifecycle approaches
Process improvement and innovation through sound scientific knowledge
Process Validation
Stage 1 – Process Design: The commercial manufacturingStage 1 – Process Design: The commercial manufacturingprocess is defined during this stage based on knowledgegained through development and scale‐up activities.
Stage 2 – Process Qualification: During this stage, theprocess design is evaluated to determine if the process iscapable of reproducible commercial manufacturing.capable of reproducible commercial manufacturing.
Stage 3 – Continued Process Verification: Ongoingi i d d i i d i h hassurance is gained during routine production that the
process remains in a state of control.
Commercial Manufacturing
Knowledge Management through review APQR
Response to assessment of data trends over time and otherk l d i dknowledge gained
Continual Improvement
CQAs and CPPs can evolve throughout the product lifecycle.
‐ Change of manufacturing process (e.g., change of synthetic route).
‐ Subsequent knowledge gained throughout the lifecycle (e.g., raw q g g g y ( gmaterial variability, pharmacovigilance, clinical trial experience, and product complaints).
How to overcome these challengesCommercial Manufacturing
Robust change Managementg g
Active knowledge Management at various stages of Productlife cycle translates to
Scientific Justification
‐ Selection of process, equipment, specification‐ Change of process, equipment, specification
P k l d ill d lProcess knowledge will grow and evolveduring product life cycle
Knowledge Management through Product life cycle
Process Development
Technology Transfer Changes
Qualification BatchesChanges
Changes
Stage2: Process Qualification
Process scale up / Q-Lots Stage1: Process design
Process Validation
Changes
Commercial Manufacturing
Change Management
Changes
CAPAAnnual Product review
Stage3: Process Verification
Challenges are overcome by
‐ Good design and control strategies‐ Good Risk Management strategiesg g‐ Good Quality SystemGood Knowledge management‐ Good Knowledge management
Effective implementation of ICH trio Q8,Q9 Q10Q9, Q10
USFDAICH
EDQM
Japan
MHRA
aliano worries!!
i know the design!!
Good design with harmonized Quality systems
TGAEDQM
ICH Q8/ Q9 / Q10 / Q11
pher
n
no worries!! i am ok for
any
design!!i have tools for any problems!!!
Development
Para
pyregulations
Qualifications
Validations
olvi
ng
Deviation/OOS
R&DQA
RA
Stability data
Evo
APRs
TT QC
Production Commercial
Stability data
Change management
Commercial
h k Thank youh @ [email protected]