Quality by Design and OINDP. Today s Presentation

Similar documents
Challenges of Implementation of ICH Q 8

Q8 and Q8 annex An industry Perspective

Quality by Design. Innovate Design Development Create value. Correct definition of QbD and its relation to product and process development

Implementing Quality Systems

ICH Q12 (Pharmaceutical Product Lifecycle Management): PMDA Perspective

ICH Q8, 9 & 10 and the Impact on the QP

Importance of ICH Guidance in Fulfilling Process Validation Requirements

STRATEGIES FOR SUCCESSFUL SCALE-UP USING QUALITY BY DESIGN

CMC Topics and PMDA s activities Yoshihiro Matsuda, Ph.D.

Quality by Design, Clinical Relevance & Lifecycle Considerations

QbD Application in Japan: PMDA Perspective

PMDA perspective on Quality by Design for pharmaceutical products

Terrence Tougas. Dennis Sandell

Value Paper. Are you PAT and QbD Ready? Get up to speed

Future of Pharmaceutical Quality and the Path to Get There

ICH Q10 Pharmaceutical Quality System

Considerations for Leachables and Extractables in a Quality by Design Environment

Analytical Methods and Sampling in the New Manufacturing Paradigm a Regulatory Perspective

ICH Q-IWG Integrated Training Programme

CDER s Office of Pharmaceutical Quality (OPQ): Delivering on the 21 st Century Quality Goals

Claus Mortensen, Medicines Inspector. Danish Medicines Agency. Member of the EMEA PAT team

Feedback EMEA / Industry Discussion

EDQM COUNCIL OF EUROPE CONFERENCE CERTIFICATION PROCEDURE : 20 YEARS OF EXPERIENCE March EDQM, Strasbourg, France ABSTRACTS

Implementation of ICH Q8 and QbD An FDA Perspective

Inter-Association Task Force

EU GMP Evolution or Revolution Scope and drivers for EU GMP changes. August Gordon Farquharson

Quality Risk Management

Office of Pharmaceutical Quality Key Quality Initiatives

Progress in FDA s Drug Product Quality Initiative. Janet Woodcock, M.D. November 13, 2003

EDQM Conference. Quality of Medicines in a Globalised World: Dreams and Reality

Global GMP Harmonisation A Japanese Perspective

OMCL Network of the Council of Europe GENERAL DOCUMENT

QUALITY: BRACKETING AND MATRIXING DESIGNS FOR STABILITY TESTING OF NEW VETERINARY DRUG SUBSTANCES AND MEDICINAL PRODUCTS

Impact of ICH Q9 and the application of Risk Management

PHARMACEUTICAL QUALITY MANAGEMENT SYSTEM: A REVIEW

Symposium on Continuous Manufacturing of Pharmaceuticals Notes

peace of mind For from development to commercial supply

Progressive Licensing and the Modernization of the Canadian Regulatory Framework

Technology Transfer Plays an Increasingly Important Role in Pharmaceutical Quality Systems

From API to Formulated Product

Association. Innovation in Medicines PDA: A Global. and Manufacturing. David Tainsh, GSK Keith Pugh, MHRA

Embracing Quality by Design. Applying QbD concepts can help CMOs create value

Convergence and Differentiation within the Framework of European Scientific and Technical Cooperation on HTA

Innovative Approaches to Pharmaceutical Development and Manufacturing Seminar Series

Implementation of Directive 2010/63/EU: - the animal welfare perspective

Extract of Advance copy of the Report of the International Conference on Chemicals Management on the work of its second session

OSIsoft. Users Conference 2013

Quality assurance in the supply chain for pharmaceuticals from the WHO perspective

MAH Responsibilities including the Management of CMOs. QP Forum Workshop. Robert Byrne and Eoin Duff Quality Assurance Alexion Pharmaceuticals

ICH Q7 - API. Presented by Ashley Isbel 4 July, 2016

WHO Regulatory Systems Strengthening Program

the SPD company Dr Clive Simon, Principal, The SPD Company.

IGDRP Mission, Scope, How it works

How CDER is Encouraging Adoption of Emerging Technologies in Pharmaceutical Industry

Health Based Exposure Limits (HBEL) and Q&As

ICH Q8 / ICH Q11 Training Course

European Commission Health and Consumers Directorate General, Brussels

The Process Analytical Technology Initiative: PAT and the Pharmacopeias

FDA s Evolving Approach to Pharmaceutical Quality

PROCESS ANALYTICAL TECHNOLOGY (PAT) - AS A CULTURE OF INNOVATION

Continuous Manufacturing, Emerging Technology and the Office of Pharmaceutical Quality

WHITE PAPER FACILITY FOCUS: Next Generation Aseptic Manufacturing: An Eye-Opening Peek into the Future. By: Hite Baker

EDQM Conference. Quality of Medicines in a Globalised World: Dreams and Reality

Building Toward a Modern Pharmaceutical Manufacturing Sector: Encouraging Development and Adoption of Emerging Technology

Global Regulatory Update FDA, USP, EP and ICH Standards for Test Method Validation. Jane Weitzel

Software as a Medical Device (SaMD)

Pharmaceutical Manufacturing and Engineering Catalog Excerpt

Challenges, benefits, case study

PDA 71 Years of Connecting People, Science and Regulation

Report OIE Animal Welfare Global Forum Supporting implementation of OIE Standards Paris, France, March 2018

USP Research & Innovation Program

MedTech Europe position on future EU cooperation on Health Technology Assessment (21 March 2017)

Gary Condran Associate Director Bureau of Pharmaceutical Sciences, Therapeutic Product Directorate, HPFB, Health Canada

Claudio Pincus, President, The Quantic Group R. Owen Richards, President, Quantic Regulatory Services Daniel Pincus, Consultant, The Quantic Group

Update on Lessons Learned from the EMA-FDA QbD Pilot

Swissmedic, Swiss Agency for Therapeutic Products

Office of Pharmaceutical Quality: Why, What, and How?

JUST SCRATCHING THE SERVICE

Getting the evidence: Using research in policy making

Annual report of the Good Manufacturing and Distribution Practice Inspectors Working Group 2017

Requirements in Other Countries PQRI+USP EI Workshop; Rockville, MD, Dr. Helmut Rockstroh

Training Prospectus Public Course Dates

MA/INS/GMP/735037/2014 Annex 1 of the GMP Guidelines on Good Manufacturing Practice - Manufacture of Sterile Medicinal Products

Position Paper on Horizon ESFRI Biological and Medical Research Infrastructures

2008 Course Programs Schedule

Foreign Particulate Matter testing using the Morphologi G3

Preparing for the new Regulations for healthcare providers

TGA Discussion Paper 3D Printing Technology in the Medical Device Field Australian Regulatory Considerations

Environmental Protection Agency

EU regulatory system for robots

Manufacture of medicinal products in Italy: challenges for the Italian Medicines Agency

Technology Transfer as the Process of Pharmaceutical Quality System: Modelling Technology Transfer as a Process Strategy

in the New Zealand Curriculum

Submission of comments on Review of the Variations Guidelines (EC 1234/2008)


SHTG primary submission process

Midwest Regional Forum. Work Smarter Not Harder Leveraging Prior Knowledge to Accelerate CMC Programs

Quality Regulation under Revised Pharmaceutical Affair Law

Analytical Development Labs

Leader in Pharmaceutical Films

Transcription:

Quality by Design and OINDP Setting the Stage John C Berridge IPAC-RS September 2008 Today s Presentation QbD definition Setting the stage from an ICH perspective Future Opportunities 2

QbD Definition Quality by Design: A systematic approach to development that begins with predefined objectives and emphasizes product and process understanding and process control, based on sound science and quality risk management. (ICH Q8R1 Step 3/4) Science and risk-based, holistic and proactive approach to product realisation that focuses on patient needs Deliberate design effort from product conception through commercialisation Full understanding of how product attributes and process relate to product quality 3 QbD is not new! Basically not totally new: EU development pharmaceutics always been done; however the PAT concept allows a better control and monitoring of process and product. The use of risk management in a Q10 type QS environment will optimise the benefit. This paradigm has been recognised by the European Commission: see Variations Public Consultation Paper (24 Oct. 2007): `Beyond the notion of 'design space', ICH developments namely the Q8, Q9, and Q10 guidelines- introduce modern tools (risk management, quality systems) that could facilitate continuous improvement of the manufacture over the products' life cycle, while maintaining a state of control that ensures high standards of quality'. J Morenas, April 2008 4

QbD is definitely not new for Device Manufacturers Taken from: Design Control Guidance For Medical Device Manufacturers FDA, March 11, 1997 5 But is QbD for OINDP new? Device and Combination Product Regulations and guidelines go back over a decade EU Annex 1 Council Directive 93/24 EEC; Pharmaceutical Quality of Inhalation and Nasal Products (CHMP/QWP/49313/2005), FDA Do it by Design (1996) MDI and DPI Drug Products -Chemistry, Manufacturing, and Controls Documentation (1998 draft) Guidance for IndustryNasal Spray and Inhalation Solution, Suspension, and Spray Drug Products -Chemistry, Manufacturing, and Controls Documentation (2002) Guidance for Industry and FDA Staff: Early Development Considerations for Innovative Combination Products (2006) 6

But many of these guidelines do not support fully current understanding of QbD They generally recognise: Systematic approach to design and realisation Quality is closely aligned with device effectiveness and performance Quality must be considered throughout lifetime of device Shared responsibility between stakeholders (including the patient) Absolute safety cannot be guaranteed They are almost universally silent on risk. Absent in EU guideline Mentioned only once each in FDA s1998 draft guidance and 2002 nasal spray guideline(relatingto extractables) Compare ISO 13485:2003 -Medical devices --Quality management systems ISO 14971:2007 -Medical devices --Application of risk management This looks like an opportunity. 7 You all know what the problem is! And you re looking to QbD thinking to solve the issues Bring our industry to the state of the art Reduce the cost of quality Re-emphasise the importance of manufacturing and manufacturing sciences Reduce waste (currently can be as high as 50%) Enable us to develop models that predict effects of scaleup Gain process understanding that supports root cause analysis of manufacturing failures Support global standards Support continual improvement and a reduction in regulatory post-approval submissions But some of you are sceptical. 8

Background: To help us all, we developed the ICH Pharmaceutical Quality Vision Develop a harmonised pharmaceutical quality system applicable across the lifecycle of the product emphasizing an integrated approach to quality risk management and science. BruxellesJuly 2003 Q8: Pharmaceutical Development (step 5) Q8: Annex (step 3) Q9: Quality Risk Management (step 5) Q10: Pharmaceutical Quality System (step 5) Q11: Manufacturing process development (step 1) 9 The Brussels 2003 Agreement Evolved and Was Confirmed in 2006 Quality Risk Management Quality Systems The Regulatory Quality System Pharmaceutical Development (Quality by Design) Existing GMP s Quality Risk Management (Q9) Pharmaceutical Development (Q8) Quality Systems (Q10) For companies with : 1. Good design and control strategies 2. Good Risk Management strategies 3. Good Quality Systems Reduced intensity of Regulatory Oversight: Reduction of submissions on changes/variations Inspection of quality systems 10

EU Regulators Vision of ICH The EU regulatory point of view on integration of different ICH quality concepts The Regulatory system Quality system Quality Risk Management (Q9) Management Quality Risk Management Pharmaceutical development Pharmaceutical Development (Q8) Existing Existing GMP GMP s Quality System (Q10) J Morenas, J-L Robert, E Cook. Sept 2007 11 Q8/9/10 Support Lifecycle Goals Pharmaceutical development Technical transfer Risk Management Knowledge Management Routine manufacturing Development Knowledge is basis for:- -manufacturing process -control strategy -process validation approach -ongoing continual improvement 12

The new Qs underwrite the new quality paradigm Product and Process Understanding Q8 & Q8 Annex Q9 Q10 Q11 Quality Risk Management Q9 Pharmaceutical Quality Systems Q10 21 st Century Quality Paradigm Lower Risk Operations Innovation and Continual Improvement Optimized Change Management Process Enhanced Regulatory Approaches 13 ICH Q9: Quality Risk Management (QRM) is straightforward A systematic process for the assessment, control, communication and review of risks to the quality of the drug (medicinal) product across the product lifecycle. To ensure both industry and regulators have common understanding of Quality Risk Management (QRM) To facilitate moving to the Desired State To facilitate communication and transparency To move from fire fighting to management of risk ICH Q9 explains A common process and language Where QRM can add value 14

Principles of QRM Two primary principles of quality risk management are: The evaluation of the risk to quality should be based on scientific knowledge (Q8) and ultimately link back to the protection of the patient. The level of effort, formality and documentation of the quality risk management process should be commensurate with the level of risk. Basically nothing new EXCEPT to encourage use of QRM 15 Q10: Pharmaceutical Quality Systems Guideline dedicated to industry- Complements ICH Q8 and ICH Q9 Augments GMPs Encourages a science & risk-based approach to quality decisions Not mandatory Applicable to: This guideline applies to pharmaceutical drug substances and drug products, including biotechnology and biological products, throughout the product lifecycle. Two enablers Knowledge Management and Quality Risk Management 16

PQS Objectives Achieve Product Realisation To establish, implement and maintain a set of processes that provides a product with the quality attributes appropriate to meet the needs of patients, health care professionals, regulatory authorities (including compliance with marketing authorisations) and internal customers. Establish and Maintain a State of Control To develop and use effective monitoring and control systems for process performance and product quality, thereby providing assurance of continued suitability and capability of processes. Quality risk managementcan be useful in establishing the monitoring and control system. Facilitate Continual Improvement To identify and implement appropriate product quality improvements, process improvements, variability reduction, innovations, and pharmaceutical quality system enhancements, thereby increasing the ability to consistently fulfil quality needs. Quality risk management can be useful to identifyand prioritise areas for improvement. Not much new for OINDP 17 Which leaves ICH Q8 Why? Regulators said that, where industry acquires extensive, systematic understanding about their product and its manufacturing process and shares this understanding with them Submissions could focus on knowledge rather than data Enhanced science and risk-based regulatory quality assessment will be possible Specifications become safety & efficacy focused New approaches to product release and process validation would be considered Post-approval processes would be examined to support innovation and continual improvement 18

Q8: Key Principles Quality cannot be tested into products; i.e., quality should be built in by design. The aim of pharmaceutical development is to design a quality product and its manufacturing process to consistently deliver the intended performance of the product. The information and knowledge gained from pharmaceutical development studies and manufacturing experience provide scientific understanding to support the establishment of the design space, specifications, and manufacturing controls. Information from pharmaceutical development studies can be a basis for quality risk management. 19 Q8 Expectations It s important to tell a compelling story At a minimum, those aspects of drug substances, excipients, container closure systems, and manufacturing processes that are critical to product quality should be determined and control strategies justified. Critical formulation attributes and process parameters are generally identified through an assessment of the extent to which their variation can have impact on the quality of the drug product. 20

Q8 Additional Opportunities.. can choose to conduct development studies that can lead to an enhanced knowledge of product performance over a wider range of material attributes, processing options and process parameters..additional information provides an opportunity to demonstrate a higher degree of understanding of material attributes, manufacturing processes and their controls. This scientific understanding facilitates establishment of an expanded design space. 21 Q8 Additional Opportunities In these situations, opportunities exist to develop more flexible regulatory approaches, for example, to facilitate: Risk-based regulatory decisions (reviews and inspections) Manufacturing process improvements, within the approved design space described in the dossier, without further regulatory review Reduction of post-approval submissions Real-time quality control, leading to a reduction of endproduct release testing But only if you describe this all in your submission 22

Q8(R) Objectives (Step 2) an annex to ICH Q8.. and provides further clarification of key concepts outlined in the core guideline. In addition, this annex describes the principles of quality by design (QbD)..shows how concepts and tools (e.g., design space) outlined in the parent Q8 document could be put into practice by the applicant for all dosage forms. Where a company chooses to apply quality by design and quality risk management (ICH Q9, Quality Risk Management), linked to an appropriate pharmaceutical quality system, then opportunities arise to enhance science-and risk-based regulatory approaches (see ICH Q10, Pharmaceutical Quality Systems). 23 An enhanced, quality by design approach to product development would additionally include the following elements A systematic evaluation, understanding and refining of the formulation and manufacturing process, including: Identifying, through e.g., prior knowledge, experimentation, and risk assessment, the material attributes and process parameters that can have an effect on product CQAs Determining the functional relationships that link material attributes and process parameters to product CQAs Using the enhanced process understanding in combination with quality risk management to establish an appropriate control strategy which can, for example, include a proposal for design space(s) and/or real-time release this more systematic approach could facilitate continual improvement and innovation throughout the product lifecycle (See ICH Q10) 24

Design Space: First referenced in FDA PAT guidance Design Space: the multidimensional combination and interaction of input variables (e.g., material attributes) and process parameters that have been demonstrated to provide assurance of quality. Working within the design space is not considered as a change. Movement out of the design space is considered to be a change and would normally initiate a regulatory post approval change process. Design space is proposed by the applicant and is subject to regulatory assessment and approval. Stop worrying so much about design space 25 Design Space can be simple or complex 12 12 Q8R Annex ACE case study www.conformia.com 26

I can feel you thinking about all the challenges Need understanding and agreement on terminology (e.g., design space) Need to determine what relevant data is needed in applications How do we get uniform global implementation? Need to determine how best to handle legacy products in line with those products developed and filed under QbD Need a regulatory agreement or post-approval management plan We re not sure how review, inspection, compliance etc fit together Everybody needs training industry and regulators OINDPsare unique -Q8 (QbD) is just for small molecules and simple drug products (Q6A) 27 Who should address the challenges? It s up to Industry to grasp the initiative and begin to lead the regulators Articulate the good science and quality risk management at conferences like this And in your submissions Be ready to contribute to revised guidance and implement it Encourage the regulators to focus on science and risk-based reviews and facilitating continual improvement We will then achieve the desired state A greater assurance of quality, improved supply reliability and security, and reduced costs. 28

Future Opportunities QbD is here, it is now, and you can use it! 29 An ICH Satellite Meeting in 2007 debated whether the principles of Q8 were applicable only to drug products from chemically derived APIs Points for consideration & common understanding Product lifecycle are there elements which should be separated out for different consideration? New Development Paradigm? applicable to substances? Elements of Quality by Design product specific? Interrelation Development / Risk management /Quality System Control Strategy applicability Design Space is it for drug products only? Future opportunities for science and risk based approaches (e.g. Real Time Release) Opportunities for extension JL Robert & JCB Sept 2007 30

Extensions???. the principles described are considered to be similarly applicable to the development of active ingredients. However, taking into account the complexity of biological molecules and processes, the application of these concepts to biological molecules will require careful consideration, and could lead to more limited use of this approach. JL Robert & JCB Sept 2007 31 Extensions??? Many of the principles are also similarly applicable to the development of analytical procedures. Adoption of the principles in this guideline can support the justification of alternative approaches to the setting of specification attributes and acceptance criteria as described in Q6A and Q6B. For example, with appropriate product and process understanding, acceptance criteria can be based on patient needs such as safety and efficacy, rather than simply on the process capability. JL Robert & JCB Sept 2007 32

Meeting conclusion QbD principles are applicable to everything we do Nothing is totally unique It s just about complexity Agreement to progress Q11 More coming today 33 IPAC-RS Strategic Plan Great ideas! QBD INITIATIVES...6 A. OINDP MATERIALS WORKING GROUP...6 B. MODEL OINDP WORKING GROUP...6 C. QBD ANALYTICAL METHOD DEVELOPMENT WORKING GROUP...7 D. QBD CORRELATIONS WORKING GROUP...7 E. RISK MANAGEMENT WORKING GROUP...7 F. QBD LEACHABLES & EXTRACTABLES FEASIBILITY GROUP...8 G. SHELF LIFE STABILITY WORKING GROUP (through PQRI)...8 H. SUPPLIER QC WORKING GROUP...8 I. CASCADE IMPACTION WORKING GROUP...9 B. MODEL OINDP WORKING GROUP Objectives To consider and explain how initiatives such as Quality by Design may be applied to OINDP. The focus of this group will be two-fold: internal, through industry discussion and education, and external, through dialogue with regulatory authorities and standard-setting bodies. Activities Developed P2 Points to Consider document providing guidance on content of P2 section of CTD for OINDP under a QbD paradigm. Visit the poster and ask how you can help! 34

IPAC-RS 2006: Stream A PAT Unclear benefits QbD offers more benefit than PAT AT is a SYSTEM with wide applicability both in development and manufacturing AT tools are key to gain enhanced process understanding AT supporting QbD and Benign by Design gives synergistic savings (1+1=3) AT is a component of QbD, not an alternative More in Tuesday morning sessions! Classical QbD process can capitalise on different control strategy Inputs Process Product Fixed (variability unknown) test & reject Fixed within univariate ranges IPC Test & reject Variable test and reject QbD Variability understood Learning adaptive to variability Reproducible minimal variability PAT Feedforward PAT Feedback PAT Feedforward PAT Feedback QbD with PAT can support Real-time Release 36

IPAC-RS 2006: Stream B Risk Assessment What is role of risk assessment in defining design space How are risk management tools applied tools are not being used to define design space Concerns of cost, time, ethical, relevance To establish critical quality attributes and process parameters See training slides on ICH website Risk assessment tools do not define design space, they help identify variables to be considered Why? Most companies have embraced concepts, even CMOs! It s not all or nothing Risk assessment should be common practice

Quality Risk Management is more than Design Space To make use of the design space concept (Q8) A powerful tool for driving rational decisions within an organisation A great vehicle for facilitating culture change When documented appropriately, provides a transparent record One of the two enables for pharmaceutical quality systems A critical component of every future regulatory submission Rapidly becoming the norm But do it properly! IPAC-RS 2006: Stream C Control Strategies How do you link control strategies to safety and efficacy No one could suggest realistic way But Regulators expect it! ONDC reorganisation: The new system will focus on critical pharmaceutical quality attributes (chemistry, pharmaceutical formulation, manufacturing process, product performance) and their relevance to safety and efficacy. EU/HC guide: Significant variations in the delivered dose and/or fine particle mass should be fully discussed in terms of the safety and efficacy of the product. This remains a key topic for all involved in the new paradigm

Control strategy should be universally applicable Control strategy : a planned set of controls, derived from current product and process understanding, that assures process performance and product quality. The controls can include parameters and attributes related to drug substance and drug product materials and components, facility and equipment operating conditions, in-process controls, finished product specifications, and the associated methods and frequency of monitoring and control. (ICH Q10 EWG) 42

The ISPE model in action S Tyler, Abbott ICH Implementation Working Group (IWG) November 2007 ICH meeting Steering Committee endorsed establishment of implementation working group Concept paper developed and conditionally approved IWG started June 2008 44

Implementation Issues Identified Technical Issues & Related Documentation Technical examples and case studies Level of detail to include in dossier Common understanding of terminology Inter-relationship between Q8, Q9, Q10 Application to both review and inspection etc. 45 Implementation Issues Identified (2) Communication and Training Additional Implementation Issues Scope of implementation: Ensuring a harmonisedapproach in these 3 areas Updating of existing guidelines No shortage of opportunities here! 46

Other opportunities? Harmonised standards Is the HC-EU guideline a potential basis for ICH? Does Q6A meet your needs? Does Q8 + Annex give sufficient guidance & flexibility? Pharmacopoeial discussion group Q4B Case studies Everybody is doing them! Examplain(NCE) and Mockestuzumab (biotech) EFPIA Analytical methods EFPIA and PhRMA Product quality lifecycle implementation (PQLI) ISPE Acetriptan(NCE), and biotech -Conformia Mock QOS (PMDA) Pilot study focused on OINDP? Pharmaceutical Development Case Study: ACE Tablets Prepared by Conformia CMC-IM Working Group March 13 th, 2008 Version 2.0 www.conformia.com 47 In conclusion:-carpe Diem Seize the opportunity and begin to realise the benefits of Q8, Q9 and Q10 (Q11) Provide significant benefit to your company NOW within the current regulatory framework Don t sit back saying, I am not going to do it until I see the regulatory flexibility Ignore the carrot of regulatory flexibility and make savings now even within the restrictions of today s regulatory environment Congratulate Regulators for their initiatives FDA s PQAS, PMP, 314.70 rewrite European Commission new variation regulations which recognise Q8/9/10 Includes dialogue with the FDA to try to harmonise on the categorisation of change Welcome start but still a way to go to achieve truly innovative regulatory approaches Lead and Contribute there are so many opportunities! PhRMA, EFPIA, JPMA, IPAC-RS, PDA, AAPS, ISPE, PQRI & other consortia There is plenty to be done, let s s get on with it! 48