A Roadmap for PAT Implementation in Pharmaceutical Manufacturing Robert M. Leasure Principal Scientist Site PAT Champion Pfizer Global Manufacturing 7000 Portage Road, PORT-91-201 Kalamazoo, MI 49001 (269) 833-6198 -1- Presentation Outline Provide some Definitions about PAT • But in the process more Questions will be asked than definitions provided. • Asking the right Questions provides the framework for successful implementations. Site perspective of a PAT program • Project Selection • Resource Allocation – from site and center support • Steps for Implementation Examples of PAT Implementations in Kalamazoo Manufacturing Ops • Drug Product Parental Sterile Suspension - improved content uniformity • Drug Product Dissolution Monitoring of Active during pH adjustment • API Operations Solvent Recovery – improved yield from timely fraction determination. -2- Definitions and Questions What is PAT? Process Analytical Technologies Things that come to mind….. Probes in Tanks Analyzers in Plant Automation Process Data (lots of it) Questions that come to mind….. Where are you going to stick that probe? How are you going to validate that system? What are you going to do with that data? -3- What is PAT? The answer is multivariate and transient. It depends on who is asking the question, and who is giving the answer. Technologists Managers $$$ Support Groups Quality and Regulatory Groups IT, Engineering, Maintenance -4- What is (a) PAT? On-line Bona fide On-line PAT System Fiber-Optic pH Probe Probe Near-Infrared Analog Spectrometer Recorder Analytical Instrument Feedback Control At-line Off-line Probe Automation Automation Pfizer Reactor Control Room vs. Sample Valve Reactor In-Plant Laboratory -5- FDA Guidance on PAT FDA Guidance Document on PAT Released in September 2004. http://www.fda.gov/cder/guidance/6419fnl.htm Ajaz S. Hussain, Ph.D. Previously Deputy Directory Office of Pharmaceutical Science, CDER, FDA Key proponent for the use of PAT in the pharmaceutical industry. -6- FDA Definition of PAT FDA Guidance – September 2004 PAT – A Framework for Innovative Pharmaceutical Manufacturing and Quality Assurance Line 158: “For the purposes of this guidance document, PAT is considered to be a system for designing, analyzing, and controlling manufacturing through timely measurements (i.e., during processing) of critical quality and performance attributes of raw and inprocess materials and processes with the goal of ensuring final product quality.” -7- Who benefits What is (a) from PAT? (a) PAT? The Users Technologists Managers $$$ Support Groups Quality and Regulatory Groups IT, Engineering, Maintenance 1. Manufacturing Operations 2. R&D or Process Scientists -8- Where does PAT begin (and end)? Involvement Co-development or Continuous Improvement Activities R&D or Manufacturing Operations Process Support * Proceed with PATs in development? PAT Project Progression "Early PAT" Used to determine Critical Process Parameters Low cost / benefit ratio "Late PAT" Used to control the process Requires formal validation -9- Why do PAT? RFT Well Controlled Process Fundamental Goals Improved quality. Improved safety. Cost savings. Process Control Process Knowledge - 11 - Continuous Quality Verification Inputs Cost Schedule Quality Process What is done on the plant floor. (Compliance) Process Analytics Action Root Cause Analysis Well Controlled Process Model D Data People Equipment Procedures Materials Metrics Evaluation Requirements - 12 - Use of PAT to Achieve RFT Benefits Reduce/eliminate deviations Improve customer service (product availability) Reduce cycle times (operational efficiency) Reduce inventory levels Reduce costs (reworks, resample, retesting, etc) Improve capacity utilization Improve compliance (reduce deviation reports) Improve assurance of quality Reduced need for end product testing is a potential consequence of RFT performance, but is not the direct goal of Pfizer’s PAT strategy. - 13 - Six Questions What ?do you wantChemical to measure? or physical property. How ?do you want toAnalytical measure it? technology. Why ?do youProcess want to measure it? Knowledge or Process Control? Where ?do youBefore, want toduring, measure? or after a process step? When ?do you wantSampling to measurefrequency. it? Who ?will look at the results? Validation….. - 14 - Considerations for Project Identification Is the process “broken”? Are there unknown or unmeasured critical process parameters? How big is the problem? What are the risks of non-conformance? What is the cost of poor throughput? Where should the measurement be made? At-line or On-line? (On-line is usually > 3x more $.) Are there area classification requirements? i.e., Class I Div I How often should a measurement be made? What are the process and instrument limitations? What decisions will be made with the data? Does Quality Operations want to intimately know the process? What are the Regulatory implications? Will implementation affect other processes? What is the impact on Cleaning Validation and probe material of construction compatibility? - 15 - PAT System Qualification PAT System Qualification and Method Validation should be based on intended use of data. Three Levels Quality Impact 1. Development or Proof of Concept No Impact 2. Information Only Indirect Impact 3. Release Decisions Direct Impact Validation or Commissioning and Qualification must conform to applicable: Corporate Quality Standards Site Procedures - 16 - Quality Impact Assessments Process Knowledge • No Impact or Indirect Impact (validation perspective) • Short term study used to assess process variability, and potential need for a permanent PAT Process Monitoring • Indirect Impact, requiring “Commissioning of Equipment” • More permanent implementation. • Monitors process to assure RFT, but not used for decision making; i.e., registered or validated assay already exists. Process Control • Direct Impact, requiring “Qualification of Equipment” • Used for - Material Release or Parametric Release - GMP Decisions for Critical to Process Parameters (CPP) - Advanced Process Control - 17 - PAT Development Resources for Kalamazoo Two main manufacturing operations: Active Pharmaceutical Ingredients • Fermentation Operations • Chemical Operations Drug Product • Sterile Injectables • Non-sterile Fluids and Ointments Site Technology Groups Kalamazoo Process Technology (KPT) Site PAT Group Center Function Support Product and Process Technology (PPT) Right First Time (Black, Green, Yellow Belts) Process Analytical Support Group (PASG) - 18 - Site Implementation Plan (SIMP) Updated annually, by PAT Champion. High level plan extending out 3 years. Approvals • Site Leadership Team (KLT) and KPT &PPT Management • US Area RFT Team Lead • PASG Implementation Team Lead Purpose 1. Track existing PAT projects 2. Identify potential new projects 3. Prioritize new and existing projects 4. Implementation Timing 5. Resource Allocation - 20 - Project Prioritization 3 1 Rank as a Percentage 10 8 3 4 3 10 76% UV-ATR Hydrogenation Reaction Monitoring API 9 7 8 7 6 7 5 8 74% NIR Process T - Ylide formation API 8 5 8 5 3 8 10 10 73% NIR Steroide B - Reaction Monitoring API 8 5 10 2 8 8 8 10 73% UV-VIS Rinsate Cleaning Optimization API 9 5 9 3 8 9 10 8 72% DP-INJ 5 8 9 1 8 8 8 10 69% OLGC SRD Distillation Monitoring API 6 3 10 6 3 2 5 10 66% Vial Headspace Analysis for Oxygen DP-INJ 8 9 8 1 3 2 5 9 61% API 3 4 8 10 5 3 5 5 60% Turbidity Dissolution Endpoint OLMS Ceplasporin Dryer Monitoring (higher is less constraigned) 6 (>$300K = 1, <$10K = 10) 8 Implementatoin Cost QO (difficult = 1, simple = 10) Raman ID of Incoming Raw Materials Project Business Area Site Specific Criterion 1 Regulatory Constraints 1 Project Complexity 3 EHS Improvement 3 Improved Efficiency or Process Improvement 2 Quality Improvement 2 Increased Process Understanding Weighting Factor: - 21 - Technology Development Process SIMP Site Implementation Plan PAT Project Ideas Justification review and project prioritization Production Quality Operations EHS Technology Groups Automation Engineering PAT Champion Tech Report on Lab POC Studies Lab proof of concept PAT Champion PASG Tech Groups Vendor PAT Project Charter Development Plant POC Report CPA (if needed) Project specific team organized PAT Champion Production Quality Ops EHS Tech Groups Automation Engineering Plant proof of concept Project Team PASG Vendor Decision to proceed Project Team Site Management PASG Adapted from an illustration by Seamus O’Neill (PASG, Ireland) - 22 - PAT ImplementationTeam Implementation of a PAT requires input from a multi-disciplinary team. PAT Champion Maintenance RFT Champion Management Manufacturing Operations Validation Services PAT Project Information Technology Automation Tech Services (KPT or PPT) PASG Engineering R&D (co-dev) Environmental, Health and Safety Quality Operations Regulatory - 23 - GAMP Model for Instrument Qualification Good Automated Manufacturing Practice User Requirements Performance Qualification Functional Specifications Operational Qualification Design Specifications Installation Qualification Installation - 24 - Q More uestions What are you going to do with the data? Is the information used for material release? Do components come into direct contact with product? Is there a GMP Impact? Is there a Regulatory Impact? Does the system affect product quality? What if the system fails? How should the data be archived? Etcetera (ca. 14 questions for a system level impact assessment) Really asking: Is the PAT for Process Knowledge or Process Control ? Answer: Quality Impact Assessment document - 25 - Implementation Process URS QIA Quality Impact Assessment Definitive CPA User Requirements Specifications Capital Project Approval FDS IQ/OQ PQ Functional Design Specifications Installation and Operation Qualification Performance Qualification Cost review, justification, Define vendor Requirements selection, and approval PAT Team PASG Project Team PASG Vendor FAT, SAT, installation, qualification Vendor Project Team PASG Validation Services Application verification Production Quality PAT Champion Lifecycle Docs • Analytical Methods • Operation SOPs • Maintenance SOPs • Training Docs • Change Control • Periodic Review •Business Continuity Plan Routine Ready for Routine Operation Operation? Cross Site Learning Adapted from an illustration by Seamus O’Neill (PASG, Ireland) - 26 - Example #1 – CU in a Sterile Suspension Application: Drug Product Sterile Aqueous Suspension Quality Impact: No Impact, Process Knowledge (product was not for sale) Objective: Improved Content Uniformity during later stages of filling operation. Project: RFT and Continuous Improvement Black Belt project to provide suggested process changes for improved content uniformity. - 27 - Drug Product – Sterile Injectable Parenteral Suspension Solid • Drug (20 - 150 mg/mL) Vehicle • Water (> 95%) • Surfactants • Preservative 2 mL vial with 1.2 mL fill - 28 - Sterile Suspension Filling Operation On-line Turbidity of Bulk Suspension Recycle Loop Off-line or At-Line NIR Analysis of Filled Vials - 29 - Potency vs. Amount Filled Lot B A Lot Off-line NIR HPLC HPLC 165 170 Potency (mg/mL) 165 160 160 155 155 150 150 145 145 RSD NIR = 0.44% 0.55% RSD HPLC = 0.83% 0.49% RSDNIR = 1.91% 3.04% RSDHPLC = 2.57% 4.47% 140 0 20 40 60 80 100 Approximate Approximate Percent Percent Filled Filled Filling operation is controlled within specifications, but there is opportunity for improvement near the end of the batch. - 30 - At-Line NIR for Suspension Vial Analysis Foss NIRSystems Model 6500 • Dispersive NIR spectrometer • fiber-optic probe Spinner - Sample Module • fiber-optic probe • in-house built accessory Vision® software Analysis time ~ 1 vial/min Non-destructive, Non-invasive - 31 - Sample Spinner Schematic sample needle bearing sleeve holder rotating gear (w = 125 rpm) fiber optic probe 45 ° mounting bracket - 32 - Apparent Concentration (mg/mL) Effect of Spin-rate on Apparent Concentration 0 rpm 250 230 210 190 25 rpm 170 50 rpm 150 125 rpm 130 0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 Time (min) - 33 - 1.4 Absorbance log(1/R) 1.2 Potency (mg/mL) Raw Near-IR Spectra 200 187 168 175 150 150 131 125 114 100 Sample 1.0 0.8 0.6 0.4 0.2 0.0 1100 1300 1500 1700 1900 2100 Wavelength (nm) - 34 - 1st Derivative Spectra 0.20 0.12 0.15 0.10 0.04 0.05 0.00 1250 st 1 Derivative 0.08 1300 1350 1400 1450 1500 0.00 0.015 -0.05 0.010 0.005 -0.10 1100 0.000 1300 1500 1700 Wavelength (nm) 1900 2100 -0.005 1600 1650 1700 1750 1800 1850 -0.010 - 35 - Near-IR Calibration 200 NIR Potency (mg/mL) 190 Partial Least Squares Model 2 factors, 1st derivative, 1650-1800 nm 180 170 160 150 140 130 Training Set (SEC = 1.28 mg/mL, R = 0.99) Test Set (SEP = 1.40 mg/mL, R = 0.99) 120 110 100 100 110 120 130 140 150 160 170 180 190 200 Lab Potency (mg/mL) - 36 - Optek Turbidity Sensor 1. Sensor Body 2. Windows 3. NIR Filter 4. Photo Diode 5. Optics Module 6. Tungsten Lamp - 37 - Calibration of On-line Turbidity Sensor Calculated Potency (mg/mL) 165 Calcuated Potency = 116.6 + 12.95 (OpSig) R² = 0.995 160 A/D Converter (volts) concentrated suspension with known amounts of vehicle. 157 153.7 3.0 Incrementally dilute a 162 158.3 mg/mL 152 148.5 2.5 147 140.9 2.0 142 137 1.5 132 1.0 Potency (mg/mL) 3.5 127 0.5 122 0.0 117 0 10 20 30 Time (min) 40 50 155 150 Correlate calculated suspension 145 potency with turbidity sensor response. 140 135 1.5 2.0 2.5 3.0 3.5 Optek Signal (volts) - 38 - DOE Study using On-line Turbidity RFT Black Belt Project to improve Content Uniformity by optimizing filling parameters. 6 factor DOE study was conducted varying mixing time, mixing power, recirculation flow-rate, etc. Tommy Garner - 39 - DOE Results Bottom mixer has minimal contribution to mixing. - 40 - DOE Results continued Mixer power is critical for consistent CU. - 41 - Improved Filling Process Proposed process change: leave mixer on longer. Three lots demonstrated no dip and no tail at end of fill. - 42 - Advantages offered by On-Line Turbidity Improved temporal sampling resolution. Cost savings, by reducing or eliminating the need to perform off-line analysis by NIR or HPLC. Note: HPLC analysis by routine labs is ca. $100/analysis. Eliminated error of taking “grab” samples for off-line analysis. This was found to be significant, if the sampling line is not properly configured, due to settling. Time savings - ability to perform several parts of the DOE during the same run, i.e., ability to see when system has become perturbed or equilibrated. - 43 - Purge Data 200 After startup of filling line following settling of suspension. Potency (mg/mL) 180 160 140 120 NIR HPLC 100 80 0 100 200 300 400 500 600 700 800 Vial - 44 - Nyquist-Shannon Sampling Theorem The sampling rate must be twice the maximum frequency component of the "signal" being measured, otherwise aliasing will occur. fsampling = 2 fsignal Graphical representations see Aliasing. Bruno A. Olshausen, PCS 129 – Sensory Processes, Oct 10, 2000. http://redwood.ucdavis.edu/bruno/npb261/aliasing.pdf - 45 - Purge Data (Short Timescale) 200 Potency (mg/mL) 180 160 140 120 NIR HPLC 100 80 0 20 40 60 80 100 120 140 160 Vial - 46 - USP Compendial CU Testing <905> “Uniformity of Dosage Units” in USP-NF Stage 1 Acceptance Criteria Assay 10 samples, i.e., n = 10 Pass if RSD ≤ 6.0% and no value is outside 85% to 115% claim. Fail if one or more value is outside 75% to 125% claim. Stage 2 Acceptance Criteria Assay 20 more samples, i.e., n = 30 Pass if RSD ≤ 7.8%, no more than one value is outside 85% to 115% claim, and no value is outside 75% to 125% claim. Statistics are based on a small sample population; i.e., analytical testing with low statistical power. - 47 - CU Testing Criteria for Large N USP <905> is unsuitable for data sets comprised of large sample populations. Proposed Acceptance Criteria outlined in article: Sandell D., Vukovinsky K., Diener M., Hofer J., Pazdan J., and Timmermans J. Development of a Content Uniformity Test Suitable for Large Sample Size. Drug Information Journal, Vol 40, pp. 337-344, 2006. - 48 - Example #2 – DP Dissolution Monitoring Objective Provide a non-qualitative means of assessing completion of API dissolution during compounding prior to aseptic filtration. Quality Impact Assessment Indirect Impact. Current IPC is by monitoring pH. Key Players Justine McKenzie Bob Witteman Tim Wang Bob Leasure Project Management Greenbelt, Manufacturing Engineer Kalamazoo Injectable Manufacturing Site PAT Support - 49 - Solu-Cortef Dissolution Monitoring Solu-Cortef is a sterile lyophilized parenteral product. The hydrocortisone API is converted to the hemisuccinate sodium salt by addition of base, with care not to exceed the specification of pH 7.8. O O O O O HO O OH O- Na O aqueous HO +Na -O + O OH O O NaOH + O- Na O NaOH HO aqueous Excess Base O O O RDWitteman conducted a RFT Greenbelt study, which concluded that slow response of the on-line pH probe can lead to OOS final pH. On-line turbidity provides a more sensitive IPC over pH. - 50 - Solu-Cortef Dissolution Monitoring - 51 - Optek Forward Scatter Turbidity Probe Optek Model AS16-N Single Channel Photometer • Forward scatter Turbidity Probe • Operates in NIR from 730 to 970 nm • OPL from 1 to 40 mm • Aseptic Ingold or Triclover fittings • Analog controller, 4-20 mA I/O (no computer) • ca. $10K - 52 - Implementation Plans Optek Turbidity Probes have been installed in two CIP compounding tanks in Kalamazoo’s new aseptic production facility. C&Q of the analyzers is underway as part of the validation of the new production facilities. Current plans are for the equipment to be used for indirect impact process monitoring. Use of the equipment for direct impact process control will be evaluated after additional process knowledge is gained and with consideration of benefits from RFT and Lean manufacturing. - 53 - Example #3 – API Solvent Recovery Application: Cost Savings by Improving Yield for Solvent Recovery in API Operations Quality Impact: Direct Impact Issues: Relatively slow determination of cut for collecting product fraction. Based on In-Plant Lab GC analysis. Project: Install On-line Gas Chromatographic analysis with associated automation. (as deemed by QO) - 54 - OLGC Installation One of seven solvent recovery columns at the site. Column #5 is used to recover seven different solvents. • DMF • Methylene Chloride • Ethyl Acetate • THF • DMAP (THF containing alcohols) • Toluene • Acetone Photo shows • Column • Still Pot • In-Plant Lab - 55 - Existing At-line GC Assay Performed by manufacturing operators in the “In-Plant Lab” (IPL) Analysis is time consuming due to manual steps: • Collect sample • Transport to IPL • Sample preparation and injection • Assay runtime, as long as 45 minutes depending on solvent Prompt for manual analysis is based on column temperatures and “wait” times indicated in Master Record - 56 - Siemens Maxum II On-line GC Dual Oven, Isothermal GC Calibration Standard Sampling Valves - 57 - On-line GC Schematic Column 2 Forward Column 1 Forward (main) Column 1 Reverse (ITC) (BF main) Detector Vents S S S R Restrictors 2 1 SSO 3 10 4 9 5 8 6 Column 1 Carrier In from EPC Column 2 7 Sample Sample Out In - 58 - Automation Backup of data files and configuration from WKS1 on AMER domain resource. Network Fileshare Storage PDH OPC Client Runs Workstation and OPC Server/ Client software interfaced to B362S927. Member of AMER domain. Gets PAT data either from APP node or directly from WKS1 PCN Switch in B362 B362OPC001 pe362hb WKS1 (B362) Controlled by Workstation software on WKS1 Runs OPC Server/ Client Interface to WKS1. Member of AMER domain. APP Node (B362S927) GC Instrument (B73) DCS (073HWL04) In-Plant Lab System - 59 - Right Oven FID (High Boiling Organics) - 60 - Right Oven TCD (Water) - 61 - Left Oven FID (Low Boiling Organics) - 62 - Method Validation Method parameters assessed during the validation using a black-box approach, but still addressing the following: ● Specificity ○ Accuracy ● Precision – Repeatability ○ Detection Limit ● Linearity ○ Range ● Quantitation Limit Component Type Major Minor Constituent acetone water methylene chloride ethyl acetate tetrahydrofuran toluene methanol ethanol * † ‡ Limits* (vol %) NLT 98.5 none none none none none NMT 0.5 none Linearity Range† (vol %) 0 to 0 to 0 to 0 to 0 to 0 to 0 to 5 5 2 2 2 2 2 Working Range‡ (vol %) 0 0 0 0 0 0 0 to to to to to to to 30 20 1 1 0.5 1 0.5 Siemens Repeatability Specification‡ ± 3% ± 0.5% ± 1% ± 1% ± 1% ± 1% ± 1% Repeatability (vol %) ± 0.9 ± 0.1 ± 0.01 ± 0.01 ± 0.005 ± 0.01 ± 0.005 NLT is not less than. NMT is not more than. The "Linearity Range" may differ from the "Working Range" and spans the region where linearity criteria are applied. Repeatability is based on Siemens specification for 8 hour repeatibility, expressed as a percentage of "Working Range". - 63 - Sample Preparation Each sample solution prepared according to the following instructions. 1. Half-fill the indicated size volumetric flask with the major component solvent. 2. Add spike volumes of each indicated neat minor component or stock solution to the flask by using Class A volumetric pipettes. For volumes greater than 20 mL, a graduated cylinder may be used to measure the volume of the minor component being added. If a stock solution is used, then only one addition of the stock is needed to meet the spike levels for minor components. 3. q.s. with the major component solvent; i.e., acetone. Stock Solutions Sample or Solution ID Major Component: acetone Limit: NLT 98.5 vol% Volume required for preps: 4100 mL Volumetric Flask Size (mL) Spike Solution vol % vol % vol % Minor Component: methylene chloride Limit: NMT 0.2 vol % Linearity Range: 0 to 5 vol % Working Range: 0 to 20 vol % Minor Component: ethyl acetate Limit: NMT 0.3 vol % Linearity Range: 0 to 2 vol % Working Range: 0 to 1 vol % Stock #2 blank 1 2 3 4 5 6 7 50 500 500 500 500 500 500 500 500 neat neat neat Stock #1 Stock #2 neat neat neat neat neat 10 10 Spike Volume (mL) 3 8 n/a n/a 8 3 20 50 150 Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage 6 16 0.120 2.4% 0.4% 15.0% 0.320 6.4% 1.1% 36.4% 1.6 32.0% 5.3% 22.2% 0.6 12.0% 2.0% 9.7% 4 80.0% 13.3% 30.3% 10 200.0% 33.3% 33.3% 30 600.0% 100.0% 75.0% 2 7 20 100 50 0.040 0.8% 0.2% 5.0% 0.160 3.2% 0.8% 18.2% 0.4 8.0% 2.0% 5.6% 1.4 28.0% 7.0% 22.6% 4 80.0% 20.0% 30.3% 20 400.0% 100.0% 66.7% 10 200.0% 50.0% 25.0% 10 2 5 0 0 0.040 2.0% 4.0% 5.0% 0.120 6.0% 12.0% 13.6% 2 100.0% 200.0% 27.8% 0.4 20.0% 40.0% 6.5% 1 50.0% 100.0% 7.6% 0 0.0% 0.0% 0.0% 0 0.0% 0.0% 0.0% 0.320 16.0% 32.0% 40.0% 0.120 6.0% 12.0% 13.6% 2 0.4 20.0% 40.0% 5.6% 5 1 50.0% 100.0% 16.1% 10 2 100.0% 200.0% 15.2% 0 0 0.0% 0.0% 0.0% 0 0 0.0% 0.0% 0.0% 0.040 4.0% 8.0% 5.0% 0.080 8.0% 16.0% 9.1% 1 0.2 20.0% 40.0% 2.8% 3 0.6 60.0% 120.0% 9.7% 6 1.2 120.0% 240.0% 9.1% 0 0 0.0% 0.0% 0.0% 0 0 0.0% 0.0% 0.0% 0.160 8.0% 16.0% 20.0% 0.040 2.0% 4.0% 4.5% 7 1.4 70.0% 140.0% 19.4% 10 2 100.0% 200.0% 32.3% 2 0.4 20.0% 40.0% 3.0% 0 0 0.0% 0.0% 0.0% 0 0 0.0% 0.0% 0.0% 0.080 4.0% 16.0% 10.0% 0.040 2.0% 8.0% 4.5% 6 1.2 60.0% 240.0% 16.7% 1 0.2 10.0% 40.0% 3.2% 3 0.6 30.0% 120.0% 4.5% 0 0 0.0% 0.0% 0.0% 0 0 0.0% 0.0% 0.0% Spike Volume (mL) 1 4 Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage 2 8 Spike Volume (mL) 1 3 2 6 Minor Component: tetrahydrofuran Limit: NMT 0.5 vol % Linearity Range: 0 to 2 vol % Working Range: 0 to 1 vol % Spike Volume (mL) Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage 8 16 3 6 Minor Component: toluene Limit: NMT 0.1 Linearity Range: 0 to 1 Working Range: 0 to 0.5 Spike Volume (mL) Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage 1 2 2 4 Minor Component: methanol Limit: NMT 0.5 vol % Linearity Range: 0 to 2 vol % Working Range: 0 to 1 vol % Spike Volume (mL) Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage 4 8 1 2 Minor Component: ethanol Limit: NMT 0.1 Linearity Range: 0 to 2 Working Range: 0 to 0.5 Spike Volume (mL) Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage 2 4 1 2 vol % vol % vol % preps from neat minor components 50 Target Level (vol %) % of Linearity Range % of Working Range Minor Component Percentage vol % vol % vol % preps from stock Stock #1 Stock Spike Volume (mL) Minor Component: water Limit: NMT 0.5 Linearity Range: 0 to 5 Working Range: 0 to 30 blank - 64 - an ol m 1 n w at e ac et et at hy e le ne ch lo rid e et hy l of ur a to lu en e et h tra hy dr te m ol an k et ha n bl e pl m 2 Sa r 3 4 0 5 6 7 1 2 Volume % 3 4 5 Sample Preparation ent mpon o C r Mino - 65 - Analyte Ratios – Assessment of Specificity 100% 90% Relative Percent of Minor Component 80% 70% ethanol methanol toluene tetrahydrofuran 60% 50% ethyl acetate methylene chloride 40% water 30% 20% 10% 0% 1 2 3 4 5 6 7 Sample # - 66 - Sample ID volume % Regression Analysis Linest Statistics 0.973113975 0.007696776 0.007619648 0.007140433 0.999693536 0.014973114 16310.13646 5 3.656637021 0.001120971 "X" Range 0 2 "Y" Fit Value 0.008 1.954 Measured (vol %) 0.000 0.219 0.176 blank Linear Regression 0.086 intercept: 0.00770 Component: 0.073 methanol slope: 0.97311 residual sum of squares: 0.00112 Limit: 0.000 0.5 correlation coefficient: 0.99910 Repeatability Specification: square of correlation coefficient: 0.99819 0.177 0.01 std error for the y-estimate of the regression line: 0.01497 0.178 0 to 2 Linearity Range: limit of detection: 0.05078 limit of quantitation: 0.15387 0.177 1 0.174 Measured 2.5 0.174 Sample Theoretical Median Average Std Dev Recovery Repeatability Median blank 0 0.175 0.080 0.092 0.090 Average 2.0 Fit 1 0.160.059 0.176 0.176 0.002 110% 0.002 Pass 0.060 2 0.04 0.060 0.060 0.001 149% 0.001 Pass 1.5 0.059 2 3 1.40.060 1.389 1.384 0.009 99% 0.009 Pass 4 2 0.060 1.948 1.948 0.014 97% 0.014 Pass 1.0 5 0.40.059 0.374 0.374 0.011 94% 0.011 Pass 6 0 1.389 0.000 0.005 0.008 0.008 Pass 0.5 7 0 1.389 0.000 0.000 0.000 0.000 Pass 1.389 Average: 110% 0.006 3 0.0 1.380 used for assessing validation criteria. Data in blue boxes 0.0 0.5 1.0 1.5 1.389 Theoretical (vol %) 1.366 1.950 1.946 Criterion 1 The slope of the linearity plot of measured volume % vs. theoretical volume % for each minor component of 1.945 4 1.950 interest must be 1 ± 0.2. 1.969 Result: Pass 1.926 0.394 0.377 Criterion 2 For each minor component of interest, the repeatability for each solution (for which six consecutive repeat 0.372 5 0.367 injections were made) must be equal to or less than the respective repeatability specification provided in 0.361 Table 1. 0.375 Result: Pass 0.019 0.013 0.000 6 Criterion 3 For each minor component of interest, the square of the regression coefficient from the plot of measured 0.000 0.000 volume % vs. theoretical volume % must be 0.99 or better. 0.000 Result: Pass 0.000 0.000 0.000 7 Criterion 4 The QL must be less than 50% the limit for the respective minor component. 0.000 0.000 Result: Pass 0.000 2.0 2.5 - 67 - Issue: Frequent Failure of Injection Rotor The variety of solvent polarity and incompatibility of MOC caused “grooving” of the injector rotor Fix involved specifying a different PTFE coated rotor. - 68 - Projected Savings The Return on Investment of the implementation was estimated to be one year, based on solvent cost and production volumes at the time of CPA submittal. Price per Gallon Approximate % of ROI Toluene $ 2.54 59% Ethyl acetate $ 3.44 20% Tetrahydrofuran $ 8.59 8% Dimethylformamide $ 3.90 7% Methylene Chloride $ 3.67 3% THF $ 8.59 2% $ 3.07 1% Solvent (alcohol containing stream) Acetone - 69 - Lessons Learned Stick to the Plan Do not deviate from define validation approach established at the beginning of the project; otherwise the project may be delayed. Train Appropriate Personnel Appropriately Cross-train key users for daily care and troubleshooting of the instrument. User training should be budgeted as part of the project scope. Keep it Simple Depending on the technology, analysis of multiple streams/products may present challenges and additional overhead. - 70 - Acknowledgements Drug Product Suspension CU • Tom Garner - RFT Black Belt and Project Manager Drug Product Dissolution Monitoring • Robert Wittemann - RFT Green Belt and Production Engineer • Tim Wang - PPT Production Engineering On-line GC for Solvent Recovery • Brad Diehl - PASG Implementation Support • Frank Sistare - PGM Groton • Joe Geiger - Production Engineering Solvent Recovery • Jeff Terpstra - Project Management • Pete Miilu, Marc Surprenant - IT Automation • Donald Zeilenga • Scott Wagenaar, Kurt Holton - Production Operations • Andrew Meister - KPT and Site PAT Support - Instrumentation Maintenance - 71 - - 72 -