IVT Laboratory Compliance Week-2013 Establishing Acceptance Criteria for Method Validation Jerry Lanese Ph.D. The Lanese Group, Inc. © 2013 The Lanese Group 1 Outline • Method Validation – Terms – Expectations – Impact of Process Validation Guidance • Acceptance criteria – Intended use – Characterstics and Types © 2013 The Lanese Group 2 Please share • Name • Job • What brought you here • One learning point you would like to take away. 3 Define • Acceptance criteria © 2013 The Lanese Group 4 Why do we validate test methods? • Good Science • The regulations require method validation 5 © 2013 The Lanese Group Testing and Release for Distribution The accuracy, sensitivity, specificity, and reproducibility of test methods employed by the firm shall be established and documented. Such validation and documentation may be accomplished in accordance with 211.194(a)(2). 21CFR211.165(e) 6 © 2013 The Lanese Group Validation Documented evidence that a system consistently performs as intended. © 2013 The Lanese Group 7 Validation of an Analytical Method The process by which it is established, by laboratory studies, that the performance characteristics of the method meet the requirements for the intended analytical applications USP <1225> © 2013 The Lanese Group 8 What to Validate The analytical performance parameters listed in the USP XXII, <1225> …… can be used as a guide for determining the analytical parameters needed to validate the method. Guide to the Inspection of Pharmaceutical; Quality Control Laboratories © 2013 The Lanese Group 9 ICH Q7 • • • • • • Analytical methods should be validated. Consider ICH Characteristics Degree of validation depends on use Maintain records Change control Verify compendial methods ICH Q7 12.8 © 2013 The Lanese Group 10 Key References • USP 1225 Validation of Compendial Procedures • ICH Q2 (R1) Validation of Analytical Procedures: Test and Methodology 11 © 2013 The Lanese Group Test method • Analytical method • Biological method • Physical method • Bioanalytical method 12 © 2013 The Lanese Group The Impact of Process Validation Guidance © 2013 The Lanese Group 13 © 2013 The Lanese Group 14 A test method is a process © 2013 The Lanese Group 15 FDA Process Validation Guidance This guidance aligns process validation activities with a product lifecycle concept and with existing FDA guidance, including the FDA/International Conference on Harmonisation (ICH) guidances for industry, Q8(R2) Pharmaceutical Development, Q9 Quality Risk Management, and Q10 Pharmaceutical Quality System.2 © 2013 The Lanese Group 16 ICH Q10 Pharmaceutical Quality System Pharmaceutical Development Technology Transfer Investigational Products Commercial Manufacturing Product Discontinuance GMP Management Responsibilities PQS Elements Process Performance and Product Quality Monitoring System Corrective Action/Preventive Action (CAPA) System Change Management System Management Review Enablers © 2013 The Lanese Group Knowledge Management Quality Risk Management ICH Q10 – 4 June 2008 Pharmaceutical Development Technology Transfer Commercial Manufacturing Product Discontinuance • Stage 1 – Process Design: The commercial process is defined during this stage based on knowledge gained through development and scale-up activities. • Stage 2 – Process Qualification: During this stage, the process design is confirmed as being capable of reproducible commercial manufacturing. • Stage 3 – Continued Process Verification: Ongoing assurance is gained during routine production that the process remains in a state of control. © 2013 The Lanese Group 18 FDA Process Validation Guidance Process Validation The collection and evaluation of data, from the process design stage throughout production, which establishes scientific evidence that the process is capable of consistently delivering quality products. involves a series of activities taking place over the lifecycle of the product and process. This guidance describes the process validation activities in three stages. © 2013 The Lanese Group 19 FDA Process Validation Guidance Validated analytical methods are not necessarily required during product- and process-development activities or when used in characterization studies. Nevertheless, analytical methods should be scientifically sound (e.g., specific, sensitive, and accurate) and provide results that are reliable FDA PV Guidance © 2013 The Lanese Group 20 Test Method Validation The collection and evaluation of data, from the method design and development, throughout material testing, which establishes scientific evidence that the method is capable of consistently delivering results that accurately reflect the material quality attribute. involves a series of activities taking place over the lifecycle of the method. © 2013 The Lanese Group 21 Lanese Product/Test Method Lifecycle Pharmaceutical Development Technology Transfer Commercial Manufacturing Material Testing Method Method Developvalidation ment & Transfer © 2013 The Lanese Group Product Discontinuance Stability Testing 22 Product Lifecycle Corporate Support and Management Operations Pharmaceutical Development © 2013 The Lanese Group GMP Technology Transfer Commercial Manufacturing 23 Product Discontinuance Product Lifecycle Corporate Support and Management Operations Pharmaceutical Development © 2013 The Lanese Group PQS Technology Transfer Commercial Manufacturing 24 Product Discontinuance • Stage 1 – Method Design: The quality control test is defined during this stage based on knowledge gained during discovery and product and method development. • Stage 2 – Method Transfer: During this stage, the method design is confirmed as being capable of reproducible performance in the quality control laboratory. • Stage 3 – Continued Method Performance Verification: Ongoing assurance is gained during routine testing that the test method remains in a state of control. © 2013 The Lanese Group 25 During development understand the test method • Determine intended use of the method • Identify the method characteristics • Identify the critical process parameters. • Establish process controls for the critical parameters. • Assure process controls adequate. • Add to the product knowledge base. • Assure that process controls are included in the test method. © 2013 The Lanese Group 26 Effective Method Development is dependent upon a clear set of requirements © 2013 The Lanese Group 27 When do we identify acceptance criteria? © 2013 The Lanese Group 28 The The Quality Control Plan Strategy Product Lifecycle Corporate Support and Management Operations Develop Discovery © 2013 The Lanese Group Commercialize Transfer 29 Decommission The organization knows many of the product related acceptance criteria the day the product is conceived. © 2013 The Lanese Group 30 Intended use • Based on – Customer requirements • Product user • Process user – Specifications • Regulatory • Internal – Product tolerances © 2013 The Lanese Group 31 As process design begins • Tentative acceptance criteria based on: – Customer requirements – Marketing expectations – Regulatory conventions – Anticipated product specifications – Production facilities – Anticipated process controls © 2013 The Lanese Group 32 At product conception: we have a good idea of: the acceptance criteria associated with these critical quality attributes. © 2013 The Lanese Group 33 We know • Final product criteria – Dosage form – Specification range – Uniformity of dose or homogeneity – Microbiological limitations • Intermediate criteria – Support the end © 2013 The Lanese Group 34 Acceptance criteria - first approximation • Assay specification range = 100% ± 10% • Test Method Measurement Uncertainty = ± 2.5% © 2013 The Lanese Group 35 Process Design Customer & Marketing requirements Process requirements Critical Quality Attributes Control Parameters Intended use Functional requirements User requirements © 2013 The Lanese Group Prototype Design Qualification 36 Formulation Process Develop Design Design space Quality Plan When do we evaluate our process/ test method against the acceptance criteria? All stages Stage 1 – Method design Stage 2 – Method validation Stage 3 – Continued method verification © 2013 The Lanese Group 37 During Method Design • Continually evaluate the test method against acceptance criteria based on the intended use of the method. • Acceptance criteria documented in a document which has some revision record. © 2013 The Lanese Group 38 At Method Validation Acceptance Criteria Established based on intended use and process design knowledge. Identified in protocol Firm © 2013 The Lanese Group 39 During continued method verification Acceptance criteria • Initially based on criteria used in validation • Revised based on product production and method use experiences and trending • Supplemented to include process capability expectations © 2013 The Lanese Group 40 Impact of guidances © 2013 The Lanese Group 41 ICH Q10 Pharmaceutical Quality System Pharmaceutical Development Technology Transfer Investigational Products Commercial Manufacturing Product Discontinuance GMP Management Responsibilities PQS Elements Process Performance and Product Quality Monitoring System Corrective Action/Preventive Action (CAPA) System Change Management System Management Review Enablers © 2013 The Lanese Group Knowledge Management Quality Risk Management ICH Q10 – 4 June 2008 PQS Elements • Process Performance and Product Quality Monitoring System • Corrective Action/Preventive Action (CAPA) System • Change Management System • Management Review © 2013 The Lanese Group 43 ICH Q10 Pharmaceutical Quality System Pharmaceutical Development Technology Transfer Investigational Products Commercial Manufacturing Product Discontinuance GMP Management Responsibilities PQS Elements Process Performance and Product Quality Monitoring System Corrective Action/Preventive Action (CAPA) System Change Management System Management Review Enablers © 2013 The Lanese Group Knowledge Management Quality Risk Management ICH Q10 – 4 June 2008 Management Process design Process qualification Continued process verification © 2013 The Lanese Group 45 ICH Q10 Pharmaceutical Quality System Pharmaceutical Development Technology Transfer Commercial Manufacturing Product Discontinuance GMP Investigational Products Management Responsibilities PQS Elements Process Performance and Product Quality Monitoring System Corrective Action/Preventive Action (CAPA) System Change Management System Management Review Enablers © 2013 The Lanese Group Knowledge Management Quality Risk Management 46 ICH Q10 – 4 June 2008 Management responsibilities Provide the organization with a clear definition of direction. Including the direction of development © 2013 The Lanese Group 47 Types of methods • Identification • Testing for impurities – Quantitative – Limit • Assay – Dissolution measurement – Content – Potency ICH Q2(R1) © 2013 The Lanese Group 48 Types of methods • Assay • Testing for impurities – Quantitative – Limit • Performance • Identification USP <1225> © 2013 The Lanese Group 49 Characteristics Analytical Performance Characteristics Parameters © 2013 The Lanese Group 50 Characteristics • Accuracy • Precision – Repeatability – Intermediate precision – Reproducibility • • • • • • © 2013 The Lanese Group Specificity Detection limit Quantitation limit Linearity Range Robustness 51 ICH Q2(R1) Method Validation Characteristics Type of procedure Accuracy Precision Repeatability Intermediate Specificity LOD LOQ Linearity Range Ident + - Impurities Quant Qual + + + + + + + + + Assay + + + + + + ICH © 2013 The Lanese Group 52 Typical Analytical Method Response Curve 800 700 600 500 400 300 200 100 0 © 2013 The Lanese Group 53 Acceptance criteria © 2013 The Lanese Group 54 What are acceptance criteria? © 2013 The Lanese Group 55 Acceptance criteria • The level of performance that a test method must achieve if the method is to perform as intended. • Each method characteristic should have appropriate acceptance criteria. • Based on critical quality attributes for the material under test. © 2013 The Lanese Group 56 Where do we get acceptance criteria From knowledge of test method and Intended use © 2013 The Lanese Group 57 The The Quality Control Plan Strategy Product Lifecycle Corporate Support and Management Operations Develop Discovery © 2013 The Lanese Group Commercialize Transfer Decommission 58 We know a lot about the testing • Active – Impurities – Stability – Degredation products • Final product – – – – Dosage form Specification range Stability Where it will be marketed • Intermediate – Support the end © 2013 The Lanese Group 59 We probably know • Where the development samples will be tested We may not know Where the commercial production quality control testing will occur Where the marketed product stability testing will occur © 2013 The Lanese Group 60 Test Method Validation Cycle Product Lifecycle © 2013 The Lanese Group 61 TEST METHOD LIFE CYCLE Start NEW METHOD FUNCTIONAL REQUIREMENTS SPECIFY INSTRUMENT IQ OQ DEVELOP METHOD Stage 1 VALIDATE METHOD Stage 2 Change Control SUBMIT IMPLEMENT SUGGEST CHANGE © 2013 The Lanese Group 62 Stage 3 Functional Requirements • How the test will be used • Specifications for the material • Where the test will be performed © 2013 The Lanese Group 63 Product 1 • API: Active A • Possible impurities (must know if > 1ppb and how much) –X –Y –Z • Will be used in sterile product © 2013 The Lanese Group 64 Product 1 – Quality Control Needs • Assay for a major component – Active A – Specification Range – 98% to 102% pure – Specificity in presence of X, Y, Z – Used for stability testing • Assay for minor components X, Y, Z – Limit of Quantitation – 1ppb – Specificity in the presence of Active A and other minor components • Test for presence of microbiological organisms © 2013 The Lanese Group 65 Product 1 – Quality Control Needs Possible tests • Assay for low level solvents • Assay or detection of starting materials • Particle size © 2013 The Lanese Group 66 Product 2 • Active: L – 0.1 mg/dosage unit • Solid dosage form – Capsule • Extended release • Excipients –A –B –C • To be marketed in Europe © 2013 The Lanese Group 67 Product 2 – Quality Control Needs • Assay for a L – Will be used for development, release and stability – Specification Range – 95% to 105% target – Possible range of assay – 0 to 115% target – Specificity in presence of A, B, C, Capsule • Test for presence of microbiological organisms © 2013 The Lanese Group 68 Functional Requirements Product 2 - Assay • Assay for the active, L – Accuracy and precision suitable for specification range of target ± 5% – Linearity suitable for defined range – Range 0 to 115% target – No interference from A, B, C, capsule materials and degredation products • Suitable for use in: – Method Development laboratory – QC laboratory – Stability laboratory © 2013 The Lanese Group 69 TEST METHOD LIFE CYCLE Start NEW METHOD FUNCTIONAL REQUIREMENTS DEVELOP METHOD VALIDATE METHOD SUBMIT IMPLEMENT SUGGEST CHANGE © 2013 The Lanese Group 70 SPECIFY INSTRUMENT IQ OQ Characteristics • • • • • • • © 2013 The Lanese Group Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation 71 Characteristics • • • • • • • © 2013 The Lanese Group Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation 72 Specificity The ability to assess unequivocally the analyte in the presence of components that may be expected to be present. Typically these might be impurities, degradants or matrix materials. © 2013 The Lanese Group 73 Specificity Required for: • Assay for major components • Tests for minor components – Quantitative – Qualitative • Identification Might be required for: • Performance © 2013 The Lanese Group 74 Nonchromatographic methods The measured concentration between samples with and without possible interfering components is not greater than the normal technique or instrument error © 2013 The Lanese Group 75 Specificity Acceptance Criteria • Chromatographic methods – The resolution between the analyte peak(s) and any other peak is at least 2. – The resolution between the impurity peak(s) and any other peak is at least 2. • if this is not possible, the difference in the assay value with and without the interfering peak(s) present is not greater than the normal instrumental error for the concentration tested. – The peak contains only one molecule. © 2013 The Lanese Group 76 Characteristics • • • • • • • Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation © 2013 The Lanese Group 77 Limit of Detection The lowest amount of analyte in a sample which can be detected, but not necessarily quantitated as an exact value . © 2013 The Lanese Group 78 Limit of Detection Required for: • Tests for minor components – Qualitative Might be required for: • Tests for minor components – Quantitative © 2013 The Lanese Group 79 FDA Guidance Always consider • Accuracy and precision against the specification range. • Precision against system suitability requirements. • Limit of detection against the impurity detection specification. • Limit of quantitation against the impurity level specification. © 2013 The Lanese Group 80 The method must be able to detect the impurity at the limit specification. NMT ≤ © 2013 The Lanese Group 81 Characteristics • • • • • • • Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation © 2013 The Lanese Group 82 Accuracy the closeness of agreement between the value which is accepted either as a conventional true value or an accepted reference value and the value found ICH Q2(R1) Generally expressed as: percent recovery percent inaccuracy compared to the theoretical © 2013 The Lanese Group 83 Accuracy Required for: • Assay for major components • Tests for minor components – Quantitative © 2013 The Lanese Group 84 Accuracy Acceptance Criteria Off the top of the head • Titration 0.5% • Chromatography 1% • Biological 10% © 2013 The Lanese Group 85 FDA Guidance Always consider • Accuracy and precision against the specification range. • Precision against system suitability requirements. • Limit of detection against the impurity detection specification. • Limit of quantitation against the impurity level specification. © 2013 The Lanese Group 86 ± 2% ± 5% ± 10% Target © 2013 The Lanese Group 87 TEST METHOD LIFE CYCLE Start NEW METHOD FUNCTIONAL REQUIREMENTS DEVELOP METHOD SPECIFY INSTRUMENT IQ OQ VALIDATE METHOD SUBMIT IMPLEMENT SUGGEST CHANGE © 2013 The Lanese Group 88 Accuracy Acceptance Criteria How are the accuracy acceptance criteria used during method development? © 2013 The Lanese Group 89 Accuracy Acceptance Criteria • For quantitative tests: – Determine from the product specification tolerance (range). The error in accuracy must be less than the product specification tolerance. Always consider accuracy and precision against the specification range. 90 © 2013 The Lanese Group Accuracy Acceptance Criteria A rule of thumb A little science – based on the intended use 91 © 2013 The Lanese Group Accuracy Acceptance Criteria • To estimate the accuracy criterion, divide the product specification tolerance by 2 to 2.5. Examples, – if the release specification for a product is 100 ± 2%, the accuracy criterion should be ~1%. – if it is 100 ± 5%, the accuracy specification should be ± 2% to 2.5%. 92 © 2013 The Lanese Group Accuracy Suggested Acceptance Criteria • For individual results – ≤ ¼ Specification limits • For the average of replicates – 0 – From a practical prospective Close to 0 © 2013 The Lanese Group 93 GoodHealth © 2013 The Lanese Group 94 Consider The impact of the accuracy acceptance criterion on measurement uncertainty © 2013 The Lanese Group 95 Characteristics • • • • • • • Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation © 2013 The Lanese Group 96 Precision The precision of an analytical procedure expresses the closeness of agreement (degree of scatter) between a series of measurements obtained from multiple sampling of the same homogeneous sample under the prescribed conditions. Precision may be considered at three levels: repeatability, intermediate precision and reproducibility. © 2013 The Lanese Group 97 ICH Q2(R1) Precision Precision should be investigated using homogeneous, authentic samples. However, if it is not possible to obtain a homogeneous sample it may be investigated using artificially prepared samples or a sample solution. The precision of an analytical procedure is usually expressed as the variance, standard deviation or coefficient of variation of a series of measurements. ICH Q2(R1) © 2013 The Lanese Group 98 Precision Method Categories Requiring This Parameter Repeatability Intermediate Reproducibility Assay of Major Components…… Yes Yes Yes Quantitative Test for Impurities... Yes Yes Yes © 2013 The Lanese Group 99 Normal instrumental and technique error contribute to the measurement uncertainty © 2013 The Lanese Group 100 FDA Guidance Always consider • Accuracy and precision against the specification range. • Precision against system suitability requirements. • Limit of detection against the impurity detection specification. • Limit of quantitation against the impurity level specification. © 2013 The Lanese Group 101 What determines acceptance criteria Measurement Material Best the measurement can do Broadest allowable Based on Derived from experimental data Uncertainty intended use Maximum Demonstrated Budget measurement measurement uncertainty uncertainty MMU DMU © 2013 The Lanese Group 102 What determines acceptance criteria MMU DMU © 2013 The Lanese Group 103 Uncertainty budget • How much uncertainty are we willing to accept? • Uncertainty budget • Rule of thumb Uncertainty budget ≤ ¼ Range © 2013 The Lanese Group 104 Range ≥ 1.33 Cp = 6MU One sided range ≥ 1.33 3MU One sided range MU ≤ 4 © 2013 The Lanese Group 105 Uncertainty Budget Range © 2013 The Lanese Group ±10% Uncertainty Budget ±2.5% ±5% ±1.25% ±2% ±0.5% ±1% ±0.25% 106 Measurement uncertainty MU = systematic error + random error Systematic error = accuracy Total random error = method precision 107 © 2013 The Lanese Group What determines acceptance criteria Measurement Material Best the measurement can do Broadest allowable Based on Derived from experimental data Uncertainty intended use Allowable Demonstrated Budget measurement measurement uncertainty uncertainty MMU DMU © 2013 The Lanese Group 108 Demonstrated Measurement Uncertainty (DME) ≤ Uncertainty Budget © 2013 The Lanese Group 109 TEST METHOD LIFE CYCLE Start NEW METHOD FUNCTIONAL REQUIREMENTS DEVELOP METHOD SPECIFY INSTRUMENT IQ OQ VALIDATE METHOD SUBMIT IMPLEMENT SUGGEST CHANGE © 2013 The Lanese Group 110 What determines acceptance criteria MMU DMU © 2013 The Lanese Group 111 Precision - Total random error Precision is related to the total random error of the analysis Total random error = © 2013 The Lanese Group √Σ 2 σ 112 Accuracy and precision Accuracy acceptance criteria + Precision acceptance criteria ≤ Uncertainty Budget (based on intended use) © 2013 The Lanese Group 113 Uncertainty Budget Range © 2013 The Lanese Group ±10% Uncertainty Budget ±2.5% ±5% ±1.25% ±2% ±0.5% ±1% ±0.25% 114 Previous guidance Specification range - ±5% Accuracy ± 2% - 2.5% Precision ± 1.5% - 2% Uncertainty Budget discussion Specification range - ±5% Accuracy + precision - ±1.25% © 2013 The Lanese Group 115 Always Consider • Accuracy and precision against the specification range. • Precision against system suitability requirements. • Limit of detection against the impurity detection specification. • Limit of quantitation against the impurity level specification. © 2013 The Lanese Group 116 Characteristics • • • • • • • © 2013 The Lanese Group Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation 117 Limit of Quantitation The quantitation limit of an individual analytical procedure is the lowest amount of analyte in a sample which can be quantitatively determined with suitable precision and accuracy. The quantitation limit is a parameter of quantitative assays for low levels of compounds in sample matrices, and is used particularly for the determination of impurities and/or degradation products. © 2013 The Lanese Group 118 ICH Q2(R1) Limit of Quantitation Required for: • Tests for minor components – Quantitative © 2013 The Lanese Group 119 FDA Guidance Always consider • Accuracy and precision against the specification range. • Precision against system suitability requirements. • Limit of detection against the impurity detection specification. • Limit of quantitation against the impurity level specification. © 2013 The Lanese Group 120 Typical Analytical Method Response Curve 700 600 500 400 300 200 100 0 © 2013 The Lanese Group 121 Characteristics • • • • • • • Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation © 2013 The Lanese Group 122 Range The range of an analytical procedure is the interval between the upper and lower concentration (amounts) of analyte in the sample (including these concentrations) for which it has been demonstrated that the analytical procedure has a suitable level of precision, accuracy and linearity. ICH Q2(R1) © 2013 The Lanese Group 123 Range Required for: • Assay for major components • Tests for minor components – Quantitative © 2013 The Lanese Group 124 Range - Guidance For the assay of a drug substance or a finished (drug) product: normally from 80 to 120 percent of the test concentration; ICH Q2(R1) Specification Limits Validation Range 80% © 2013 The Lanese Group 90% 100% 125 110% 120% Range - Guidance For content uniformity: a minimum of 70 to 130 percent of the test concentration, unless a wider more appropriate range, based on the nature of the dosage form (e.g., metered dose inhalers), is justified; ICH Q2(R1) Specification Limits Validation Range 70% © 2013 The Lanese Group 90% 100% 126 110% 130% Range - Guidance • for dissolution testing: +/-20 % over the specified range; ICH Q2(R1) Time (hr) 1 3 6 9 12 © 2013 The Lanese Group % Released 20%-40% 40%-75% 50%-80% 60%-90% >80% Range: 0% to 120% 127 Characteristics • • • • • • • Specificity Accuracy Precision Linearity Range Limit of Detection Limit of Quantitation © 2013 The Lanese Group 128 Linearity The ability (within a given range) to obtain test results which are directly proportional to the concentration (amount) of analyte in the sample. ICH Q2(R1) © 2013 The Lanese Group 129 Linearity may be demonstrated directly on the drug substance (by dilution of a standard stock solution) and/or separate weighings of synthetic mixtures of the drug product components, using the proposed procedure. ICH Q2(R1) © 2013 The Lanese Group 130 Linearity Required for: • Assay for major components • Tests for minor components – Quantitative © 2013 The Lanese Group 131 Linear regression analysis Coefficient of variation Major analyte - ≥ 0.999 Minor analyte - ≥ 0.98 Intercept = zero 95% confidence Visual analysis Straight line Zero intercept © 2013 The Lanese Group 132 IVT Laboratory Compliance Week-2013 Establishing Acceptance Criteria for Method Validation Jerry Lanese Ph.D. The Lanese Group, Inc. © 2013 The Lanese Group 133 Contact Information Jerry Lanese Ph.D. The Lanese Group,, Inc. 12401 Catalina Leawood, KS 66209 913 491 9234 jerry@lanesegroup.com www.lanesegroup.com © 2013 The Lanese Group 134