from manufacturing to the vaccinee – the complex journey of a … · 2018-04-02 · international...
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International Federation of Pharmaceutical Manufacturers & Associations
From Manufacturing to the Vaccinee – the Complex Journey of a Vaccine David K. Robinson, Ph. D. Vice President, Biologics Head and Executive Director, Biologics and Vaccines CMC Regulatory Merck & Co, Inc. Presenting on behalf of the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) WCBP CASS, Washington DC, USA January 2014
1 January, 2014
Introduction: Impact of Vaccines on Human Health I. The Complexity of Vaccines II. The Complexity of the Manufacturing
Pathway III. The Complexity of the Regulatory Approval
2 January, 2014
Access to Vaccines • Vaccines have a tremendous positive impact
on human health globally • Access to vaccines remains important
January, 2014 3
© IFPMA 2012 4
http://www.hhs.gov/nvpo/concepts/intro6.htm
The dramatic impact of vaccines on human health
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http://www.hhs.gov/nvpo/concepts/intro6.htm
The dramatic impact of vaccines on human health
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Mumps-United States, 1968-1996
http://www.hhs.gov/nvpo/concepts/intro6.htm
The dramatic impact of vaccines on human health
© IFPMA 2012 7
Mumps-United States, 1968-1996
Rubella-United States, 1966-1996
http://www.hhs.gov/nvpo/concepts/intro6.htm
The dramatic impact of vaccines on human health
© IFPMA 2012 8
HiB-United States, 1981-1995
Mumps-United States, 1968-1996
Rubella-United States, 1966-1996
http://www.hhs.gov/nvpo/concepts/intro6.htm
The dramatic impact of vaccines on human health
Vaccination efforts helped reduce the incidence of disease in Africaa
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a Countries include: Algeria, Angola, Benin, Botswana, Burkina Faso, Burundi, Cameroon, Cape Verde, Central African Republic, Chad, Comoros, Republic of the Congo, Cote d’lvoire, Democratic Republic of the Congo, Equatorial Guinea, Eritrea, Ethiopia, Gabon, Gambia, Ghana, Guinea, Guinea-Bissau, Kenya, Lesotho, Liberia, Madagascar, Malawi, Mali, Mauritania, Mauritius, Mozambique, Namibia, Niger, Nigeria, Rwanda, Sao Tome and Principe, Senegal, Seychelles, Sierra Leone, South Africa, Swaziland, Togo, Uganda, United Republic of Tanzania, Zambia, and Zimbabwe.
Percentage disease reduction in Africa from 1980 to 20091
83%93%
73%
33%
96%100%
Diphtheria Pertussis Neonatal tetanus
Total tetanus Measles Polio
References: 1. World Health Organization (WHO). WHO Vaccine-Preventable Diseases: Monitoring System. 2010 Global Summary. http://whqlibdoc.who.int/hq/2010/WHO_IVB_2010_eng.pdf. Accessed January 3, 2012. 2. World Health Organization (WHO). http://www.who.int/about/regions/afro/en/index.html. Accessed March 12, 2011.
Percentage disease reduction in Africa from 1980 to 20091
Vaccination efforts helped reduce the incidence of disease in the Americasa
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a Countries include: Antigua and Barbuda, Argentina, Bahamas, Barbados, Belize, Bolivia (Plurinational State of), Brazil, Canada, Chile, Colombia, Costa Rica, Cuba, Dominica, Dominican Republic, Ecuador, El Salvador, Grenada, Guatemala, Guyana, Haiti, Honduras, Jamaica, Mexico, Nicaragua, Panama, Paraguay, Peru, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Suriname, Trinidad and Tobago, United States of America, Uruguay, and Venezuela (Bolivarian Republic of). References: 1. World Health Organization (WHO). WHO Vaccine-Preventable Diseases: Monitoring System. 2010 Global Summary. http://whqlibdoc.who.int/hq/2010/WHO_IVB_2010_eng.pdf. Accessed January 3, 2012. 2. World Health Organization (WHO). http://www.who.int/about/regions/amro/en/index.html. Accessed March 12, 2011.
Percentage disease reduction in the Americas from 1980 to 20091
100%100%92%98%94%99%
Diphtheria Pertussis Neonatal tetanus
Total tetanus Measles Polio
Percentage disease reduction in the Americas from 1980 to 20091
Vaccination efforts helped reduce the incidence of disease in Southeast Asiaa
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a Countries include: Bangladesh, Bhutan, Democratic People’s Republic of Korea, India, Indonesia, Maldives, Myanmar, Nepal, Sri Lanka, Thailand, and Timor-Leste. References: 1. World Health Organization (WHO). WHO Vaccine-Preventable Diseases: Monitoring System. 2010 Global Summary. http://whqlibdoc.who.int/hq/2010/WHO_IVB_2010_eng.pdf. Accessed January 3, 2012. 2. World Health Organization (WHO). http://www.who.int/about/regions/searo/en/index.html. Accessed March 12, 2011.
Percentage disease reduction in Southeast Asia from 1980 to 20091
96%86%
97%89%
99%99%
Diphtheria Pertussis Neonatal tetanus
Total tetanus Measles Polio
Percentage disease reduction in Southeast Asia from 1980 to 20091
1. Eurosurveillance. Vol. 12; 8, Feb. 22, 2007. http://www.eurosurveillance.org/ViewArticle.aspx?PublicationType=W&Volume=12&Issue=8&OrderNumber=1. Accessed April 5, 2011. 2. Eurosurveillance, Vol. 15; 23, June 10, 2010. http://www.eurosurveillance.org/ViewArticle.aspx?ArticleId=19586. Accessed April 5, 2011. 3. World Health Organization (WHO). Epidemiological Brief. Oct. 25, 2010. http://www.reliefweb.int/rw/rwb.nsf/db900SID/EGUA-8AUR9R?OpenDocument. Accessed April 5, 2011. 4. World Health Organization (WHO). Global Alert and Response (GAR). Nov. 13, 2010. http://www.who.int/csr/don/2010_11_13/en/index.html. Accessed April 5, 2011. 5. CDC. Outbreak Notice. March 18, 2011. http://wwwnc.cdc.gov/travel/content/outbreak-notice/polio-tajikistan-russia-central-asia.aspx. Accessed April 5, 2011. 6. CDC. March 15, 2011. http://www.cdc.gov/pertussis/outbreaks.html. Accessed April 5, 2011. 7. HealthMap. Global Health, Local Information. December 2010. http://healthmapblog.blogspot.com/2010_12_01_archive.html. Accessed April 19, 2011. 8. ISID. August 9, 2010.ttp://promedmail.org/pls/otn/f?p=2400:1001:333553816968016::NO::F2400_P1001_BACK_PAGE,F2400_P1001_PUB_MAIL_ID:1010,84066. Accessed April 5, 2011. 9. World Health Organization (WHO). Global Alert and Response (GAR). March 8, 2011. http://www.who.int/csr/don/2011_03_08/en/index.html. Accessed April 5, 2011. 10. Global Poliio Eradication Initiative. January 15, 2014.. http://www.polioeradication.org/Dataandmonitoring/Poliothisweek.aspx.. Accessed January 22, 2014. 11. Centers for Disease Control. http://www.cdc.gov/measles/outbreaks.html. Accessed January 22, 2014
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Access to Vaccines and Robust Vaccination Remains Important
• Outbreaks of vaccine-preventable diseases still occur throughout the world (some selected examples)
– Polio: Although India has gone three years without a case, nearly 500 cases were reported in Tajikistan throughout 2010, leaving 2 children paralyzed. Six new cases reported in just a single week this year (2014) in Pakistan.
– Mumps: From January 2008 through June 2009, there were 16,352 notifications of cases in Macedonia.
– Measles: From October , 2006, to January, 2007, there were 213 confirmed cases in Barcelona, Spain. From January 1 to August 24, 2013, 159 cases were reported in the United States (despite measles being declared officially eradicated in 2000).
Complexity of Vaccines – Vaccines are structurally complex – Vaccines of consistent quality are complex
to manufacture – The need to provide protection against
multiple serotypes of an infectious agent increases the complexity
January, 2014 13
- -
Human Papilloma Virus Virus Like Particle
(Prophylactic Vaccine) MW ~ 20,000,000 Da IgG Immunoglobin
(Therapeutic mAb) MW ~ 150,000 Da
Vaccines are structurally complex
Simvastatin (Cholesterol Lowering)
MW ~ 200 Da
14
Vaccines can contain multiple components
• 90% of cervical cancers worldwide are attributed to 7 HPV types
• Second generation investigational HPV vaccine being developed for the prevention of cervical, vulvar, and vaginal cancers contains these 7 high risk HPV types, plus an additional 2 HPV types
• Each of these 9 HPV types is prepared as a separate Drug Substance and combined in the vaccine.
1 de SanJose, et al., The Lancet. 2010.
Impact of Adding 5 New HPV Types to Existing Quadrivalent
Vaccine1
0 20 40 60 80 100
V503
GARDASIL
Cumulative Attributed Prevalence (%)
70%
~90%
HPV 16 HPV 18 HPV 45 HPV 31
HPV 33 HPV 52 HPV 58
Quadrivalent
Investigational Nine-valent
January, 2014 15
• Multicomponent polysaccharide vaccine indicated for active immunization for the prevention of pneumococcal disease caused by the serotypes contained in the vaccine
• Contains 23 different bacterial polysaccharides
• Each of these 23 polysaccharides is manufactured as a separate drug substance
Vaccines can contain multiple components
January, 2014 16
P
O
OH
OOH
OHCH3
O
O
O
O
OH
OH
CH2
OHC
NH
CH3
O
OO
OH
CH2
OH
Serotype 19A1
1) Katzenellenbogen, E., Jennings, H. J., Structural determination of the capsular polysaccharide of Streptococcus pneumoniae type 19A(57), Carbohydr. Res., 124, 235, 1983
Each step has multiple unit operations
January, 2014 17
Raw materials
Harvesting
Purification
Valence Blending Adjuvant
Adsorption
Aseptic Filling
Packaging Aseptic Filling
Fermen-tation or cell culture
Quality: quality control, quality assurance
January, 2014 18
Raw materials
Harvesting
Purification
Valence Blending Adjuvant
Adsorption
Aseptic Filling
Packaging Aseptic Filling
Fermen-tation or cell culture
Quality: quality control, quality assurance
Capture Chromatography
Ultrafiltration
Sterile Filtration
Polishing Chromatography
Each step has multiple unit operations
January, 2014 19
Raw materials
Harvesting
Purification
Valence Blending Adjuvant
Adsorption
Aseptic Filling
Packaging Aseptic Filling
Fermen-tation or cell culture
Quality: quality control, quality assurance
Capture Chromatography
Ultrafiltration
Sterile Filtration
Polishing Chromatography
Each of the Drug Substance unit operations need to be individually optimized, demonstrated and executed for each of the individual polysaccharides, proteins and/or viruses in a multivalent vaccine (x4, x9, x23)
Each step has multiple unit operations
Regulatory approval of vaccines can be complex • Manufacturing process changes may be
required to increase access to necessary vaccines
• These changes may require regulatory submissions
• If licensed in multiple countries (10 to 130), multiple filings will be required
January, 2014 20
Processes for vaccines are continuously improved (Variations)
• Optimized Manufacturing Processes • Capacity Increases
– Scale-up – New or Expanded Facility
• Analytical – Improved methods – Changes in specifications as a result of agency
questions during initial review – Changes in specification as a result of improved
process capability • Unplanned Changes outside of Sponsor’s
Control (e.g., Components, Raw Materials) • Market Preferences for Local Manufacturing • New Regulatory Requirements
Many of the changes introduced to improve the vaccine process or increase vaccine access require regulatory notification and/or approval
January, 2014
Case Studies* (3 in total) Manufacturer intends to increase capacity to enhance global access to a vaccine I. Add vaccine product facility to increase
productivity II. Change lyophilization cycle to increase productivity III. Multiple improvements to increase capacity
22
* Regulatory requirements around the globe are very dynamic; therefore all sponsors should conduct their own regulatory assessments for any planned changes
January, 2014
Case Study I: Filing Requirements for New Vaccine Product Facility (>130 countries, approval of a post-marketing change)
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Case Study I: Filing Requirements for New Drug Product Facility (>130 countries, approval of a post-marketing change)
Time to Approval (months) 0 5 10 15 20 25 30
1
2
3
4
5
6
7
8
9
1…
1…
1…
1…
1…
1…
1…
1…
1…
1…
2…
Series1
Indi
vidu
al N
atio
nal/R
egio
nal
Hea
lth A
utho
ritie
s
Case Study II: Stability Data and Approval Times for Change in Lyophilization Cycle (>20 countries, approval of a post-marketing change)
January, 2014 25
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Time to Approval (months) 0 5 10 15 20 25 30
1
2
3
4
5
6
7
8
9
1…
1…
1…
1…
1…
1…
1…
1…
1…
1…
2…
Series1
Pre-approval not required
No stability data required in submission
Require 6 months stability data
Require 3 months stability data
Require US/EU approval or CPP (Certificate of Pharmaceutical Product) prior to submission or during review
Indi
vidu
al N
atio
nal/R
egio
nal
Hea
lth A
utho
ritie
s
Case Study II: Stability Data and Approval Times for Change in Lyophilization Cycle (>20 countries, approval of a post-marketing change)
January, 2014
Case study III Manufacturer intends to increase capacity to enhance global access to a vaccine I. Add additional vaccine product facility to increase
productivity AND II. Change “lyo” cycle to increase productivity AND III. Change facility design to comply with new regulations
(Annex II)
27 January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Takes Even Longer to Get A Change Approved in All Countries
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
Can take an extra 2 years to get approval in last 20% of countries
0 1 2 3 4 5 6 7 8 Years January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Takes Even Longer to Get Multiple Changes Approved
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
Might file next change before approvals have been received in all
countries
January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Takes Even Longer to Get Multiple Changes Approved
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
Might then file a third change
January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
Some countries will only review one change at
a time
Takes Even Longer to Get Multiple Changes Approved
January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Takes Even Longer to Get Multiple Changes Approved
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
This can add 3 years or more
before approval in all countries
January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Overlapping Approvals Increase Supply Complexity
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
Two versions (pre- and post-change
1) in inventory
January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Overlapping Approvals Increase Supply Complexity
Lag between filings
Approval in 20% of Countries
Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
Two versions (pre- and post-change
1) in inventory
Three versions in inventory
January, 2014
0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0
1
2
3
Series1Series2Series3Series4Series5Series6
Overlapping Approvals Increase Supply Complexity
Lag between filings
Approval in 20% of Countries Approval in 40% of Countries
Approval in 60% of Countries
Approval in 80% of Countries
Approval in 100% of Countries
Cha
nge
Num
ber
1
2
3
0 1 2 3 4 5 6 7 8 Years
Two versions (pre- and post-change
1) in inventory
Three versions in inventory
Four versions in inventory
January, 2014
Testing of Vaccines can be Complex • Vaccines undergo multiple tests for release • Some countries require redundant lot-specific
testing prior to release • Some countries have unique compendial
testing requirements
January, 2014 36
Each Vaccine is Tested via Dozens of Methods during Quality Control
January, 2014 37
Raw materials
Harvesting
Purification
Valence Blending Adjuvant
Adsorption
Aseptic Filling
Packaging Aseptic Filling
Fermen-tation or cell culture
Quality: quality control, quality assurance
Subset of Release Tests for Hib Conjugate Vaccine • pH • Identity • Carrier protein content • Adjuvant content • Residual moisture • Sterility • Pyrogen content • Preservative content • General safety test (Innocuity)
abnormal toxicity • Free carrier protein
Each Vaccine is Tested via Dozens of Methods during Quality Control
January, 2014 38
Raw materials
Harvesting
Purification
Valence Blending Adjuvant
Adsorption
Aseptic Filling
Packaging Aseptic Filling
Fermen-tation or cell culture
Quality: quality control, quality assurance
Subset of Release Tests for Hib Conjugate Vaccine
• pH • Identity • Carrier protein content • Adjuvant content • Residual moisture • Sterility • Pyrogen content • Preservative content • General safety test (Innocuity)
abnormal toxicity • Free carrier protein
All non-compendial methods require transfer of methods, equipment and reagents to local & national testing labs
Redundant Testing Increases the Cost and Time to Get a Vaccine to Those in Need
• Each lot of vaccine is tested by the Manufacturer prior to release • These same tests may be repeated by the official national control
laboratory prior to export • Then, these same tests may be repeated again by the importing country • All vaccines have a limited shelf life • The time it takes for this redundant testing can leave little time left to
distribute and administer the vaccine to those who most need it
39
Test X done by the
manufacturer
Test X repeated by the official
national test lab prior to export
Test X repeated again by the
importing country
Time left for distribution and
administration of the vaccine
Shelf-life (time from date of manufacture to expiry) of vaccine
Test time varies, depending on each vaccine, each test and the capacity and capability of each testing laboratory
Remaining time within which
individual lot of vaccine can be
distributed January, 2014
40
The Duplication of Reviews and Redundancy of Testing Add Complexity
• Much of the regulatory review and testing is similar, but much is also individualized: – Many countries have specific national regulatory requirements that
must be complied with. – The regulatory review time and complexity is further increased by the
lack of recognition between Health Authorities; “all repeat the same review” which creates a continuous review process.
– Multiple countries repeat release testing upon importation, even if that release testing has already been independently conducted by internationally recognized Health Authorities
– Consequently further increases review time and release times, delaying the ability to provide access to patients.
January, 2014
Challenges: Compendial Changes • Lack of harmonization across compendia adds complexity to regulatory
compliance & surveillance, in addition to vaccine development and supply – WHO: 140 independent countries are using >30 pharmacopoeias
(across national, regional, and international) • Lack of consistent communication & industry representation during the
process of revising compendia forces manufacturers to be reactive v. pro-active – Potentially could impact compliance and disrupt the supply chain
• Impact across range of drug products may not be well understood without input from industry – For example: adding a requirement that may be a minor change for a
small molecule has a greater impact to a Live Virus Vaccine due to increasing complexity:
41
Small Molecules Biologics Live Virus Vaccines
January, 2014
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Increased regulatory complexity • High rigor in regulatory standards and reviews help
to ensure the quality of vaccines around the world – Reflecting the complexity of vaccine (composition, methods of
manufacture, testing procedures), technical registration files are increasing in size and complexity
– Resource constraints limit the ability to quickly review these increasingly complex submissions and to quickly conduct local testing
January, 2014
43
Increased regulatory complexity • High rigor in regulatory standards and reviews help
to ensure the quality of vaccines around the world – Reflecting the complexity of vaccine (composition, methods of
manufacture, testing procedures), technical registration files are increasing in size and complexity
– Resource constraints limit the ability to quickly review these increasingly complex submissions and to quickly conduct local testing
• However: – Redundant reviews may not greatly increase the assurance
of product quality – Additional testing, beyond that conducted by the manufacturer
and internationally recognized health authorities, adds little contribution in terms of additional assurance of the safety of the product
January, 2014
To reduce regulatory complexity and enhance access to vaccines • Harmonize compendial requirements and
provide for systems to update compendia • Harmonize data and information
requirements to streamline submission preparation
• Engage in mutual recognition of internationally recognized health authorities output to reduce: – Redundant reviews of submissions – Redundant testing of vaccine lots – Redundant facility inspections
44 January, 2014
45
Conclusion
• Vaccines are an important component in improving and maintaining public health around the globe
• New, complex vaccines, high quality standards and the evolving regulatory environment combine to create a non sustainable situation, where the ability to enable access to patients can be hindered
• To sustain worldwide access to vaccines, the regulatory environment needs to adapt.
• Harmonization of regulatory requirements, partnerships in the review of applications, alignment on compendial methods, and a reduction in redundant testing would facilitate access
January, 2014
Vaccines help save lives
46
“With the exception of safe water, no other modality, not even antibiotics, has had such a major effect on mortality reduction and population growth.” 1
Stanley A. Plotkin, MD Vaccine developer Emeritus Professor of Pediatrics University of Pennsylvania Emeritus Professor, Wistar Institute
Reference: 1. Plotkin SL et al. In: Plotkin SA et al. Vaccines. 5th ed. Saunders; 2008:1–16.
January, 2014
IFPMA-in-brief Global, non-profit NGO with over 40 years of advocacy experience in
the international arena Based in Geneva, IFPMA has official relations with the UN, including
the World Health Organization (WHO), World Intellectual Property Organization (WIPO), and the World Trade Organization (WTO)
IFPMA membership: • research-based pharmaceutical industry, including the
biotechnology and vaccine sectors • national industry associations
Mission: The IFPMA advocates policies that encourage discovery of and access to life-saving and life-enhancing medicines to improve the health of people everywhere
47 January, 2014