2-4 ICH Quality Guidances: an overview PQP Assessment Training January 18-21, 2012 Satish Mallya 1| January20-22, 18-21,2010 2012 Satish Mallya January ICH Topics Stability - Q1A – Q1F Analytical Validation – Q2 Impurities – Q3A - Q3C (Q3D – concept paper) Pharmacopoeias – Q4A - Q4B (and annexes) Quality of Biotechnological Products – Q5A – Q5E Specifications – Q6A – Q6B Good Manufacturing Practice – Q7 Pharmaceutical Development – Q8 Quality Risk Management - Q9 Pharmaceutical Quality System – Q10 Development and Manufacturing of Drug Substances – Q11 2| January20-22, 18-21,2010 2012 Satish Mallya January Focus Stability - Q1A, B, C, D, E & F Validation of Analytical Methods – Q2(R1) Impurities – Q3A, B & C Specifications – Q6A (Chemical Substances) & Q6B (Biotechnology/Biological Products) 3| January20-22, 18-21,2010 2012 Satish Mallya January Stability Q1A(R2) Stability Testing of New Drug Substances and Products Q1B Photostability Testing of New Drug Substances and Products Q1C Stability Testing for New Dosage Forms Q1D Bracketing and Matrixing Designs for Stability Testing of New Drug Substances and Products Q1E Evaluation of Stability Data Q1F Stability Data Package for Registration Applications in Climatic Zones III & IV (withdrawn – June 2006) 4| January20-22, 18-21,2010 2012 Satish Mallya January Q1A(R2) STABILITY TESTING OF NEW DRUG SUBSTANCES AND PRODUCTS Drug Substance Drug Product Stress testing Photostability testing Selection of batches Selection of batches Container closure system Container closure system Specification Specification Testing frequency Testing frequency Storage conditions Storage conditions Stability commitment Stability commitment Evaluation Evaluation Statements/Labeling Statements/Labeling 5| January20-22, 18-21,2010 2012 Satish Mallya January Stress Testing/Photostability Drug Substance Drug Product One primary batch One primary batch Effect of temperatures (in 10°C increments (e.g., 50°C, 60°C, etc.) above that for accelerated testing) As in ICH Q1B: Effect of humidity (e.g., > 75%RH) 6| January20-22, 18-21,2010 2012 Satish Mallya January Selection of Batches Drug Substance Data on at least three primary batches of minimum pilot scale manufactured by the same synthetic route as used for production batches. Drug Product Data on at least three primary batches of the drug product – two pilot and third one can be smaller - same formulation and packaged in the same container closure system as proposed for marketing. The manufacturing process used for primary batches should simulate that to be applied to production batches Where possible, use different batches of the drug substance. Should be performed on each individual strength and container size of the drug product unless bracketing or matrixing is applied. 7| January20-22, 18-21,2010 2012 Satish Mallya January Container Closure System Drug Substance Drug Product Studies to be conducted on the API packaged in a container closure system that is identical to or simulates the proposed commercial packaging Studies to be carried out in container closure system identical to commercial packaging; studies carried out in other packaging materials can be used as supporting information 8| January20-22, 18-21,2010 2012 Satish Mallya January Specification Drug Substance Studies to include attributes susceptible to change during storage and which can influence quality, safety and efficacy: - Physical - Chemical - Microbiological Validated analytical methods to be employed 9| 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Drug Product Studies to include attributes susceptible to change during storage and which can influence quality, safety and efficacy: - Physical - chemical, - microbiological, - preservative content - functionality tests (e.g. with delivery systems) Validated analytical methods to be employed Testing Frequency Drug Substance Drug Product For API with proposed re-test period/shelf-life of at least 12 months: Every 3 months over first year, every 6 months over next 12 months and annually thereafter. For FPP with proposed re-test period/shelf-life of at least 12 months: Every 3 months over first year, every 6 months over next 12 months and annually thereafter. Accelerated condition: Minimum of 3 time points, including initial and final time points (e.g. 0, 3 & 6 months) Accelerated condition: Minimum of 3 time points, including initial and final time points (e.g. 0, 3 & 6 months) Intermediate condition (due to significant change under accelerated condition): study design should include 4 time points (e.g. 0, 6, 9 and 12 months Intermediate condition (due to significant change under accelerated condition): study design should include 4 time points (e.g. 0, 6, 9 and 12 months) Matrixing or Bracketing may be applied 10 | 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Storage Conditions Drug Substance Drug Product General Case Study Storage Conditions Minimum period covered by data at submission Study Storage Conditions Minimum period covered by data at submission Long term 25⁰C+2⁰C/ 60%+5%RH or 30⁰C+2⁰C /65% +5%RH 12 months Long term 25⁰C+2⁰C /60%+5%RH or 30⁰C+2⁰C /65% +5%RH 12 months Intermediate 30⁰C+2⁰C /65% +5%RH 6 months Intermediate 30⁰C+2⁰C /65% +5%RH 6 months Accelerated 40⁰C+2⁰C /75% +5%RH 6 months Accelerated 40⁰C+2⁰C /75% +5%RH 6 months 11 | 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Storage Conditions Storage in refrigerator Drug Substance Drug Product Study Storage Conditions Minimum period covered by data at submission Study Storage Conditions Minimum period covered by data at submission Long term 5⁰C + 3⁰C 12months Long term 5⁰C + 3⁰C 12months Accelerated 25⁰C + 2⁰C / 60% 6 months + 5% RH Accelerated 25⁰C + 2⁰C / 60% 6 months + 5% RH 12 | 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Storage Conditions Storage in freezer Drug Substance Study Storage Conditions Long term - 20⁰C + 5⁰C Minimum period covered by data at submission 12months Drug Product Study Storage Conditions Long term - 20⁰C + 5⁰C Storage below - 20⁰C : Case by case basis 13 | 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Minimum period covered by data at submission 12months Storage Conditions – Drug Product Semi-permeable containers : Study Storage Conditions Minimum period covered by data at submission Long term 25⁰C+2⁰C/40%+5% RH or 30⁰C+2⁰C/35%+5% RH 12 months Intermediate 30⁰C+2⁰C/65%+5% RH 6 months Accelerated 40⁰C+2⁰C/NMT 25% RH 6 months 14 | 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Significant Change Drug Substance Drug Product Defined as failure to meet specifications ->5% change in assay from the initial results -Any degradation product exceeding its acceptance criterion -Failure to meet acceptance criteria for appearance, physical attributes and functionality tests -Failure to meet acceptance criteria for pH -Failure to meet acceptance criteria for dissolution of 12 dosage units 15 | January20-22, 18-21,2010 2012 Satish Mallya January Evaluation Drug Substance Statistical analysis not necessary if data exhibits little or no degradation and variability Drug Product Statistical analysis not necessary if data exhibits little or no degradation and variability Limited extrapolation of real time data Limited extrapolation of real time data permitted with justification permitted with justification 16 | 20-22, June 2010 January 18-21,2010 2012 Satish Mallya January Q1B PHOTOSTABILITY TESTING OF NEW DRUG SUBSTANCES AND PRODUCTS Provides 2 options for sources of light: – artificial daylight fluorescent lamp combining visible and ultraviolet (UV) outputs, xenon, or metal halide lamp – sample should be exposed to both the cool white fluorescent and near ultraviolet lamp Test on API first – if not photosensitive then no further testing is required If API is photosensitive then testing to be continued on (as appropriate): – Tests on the exposed drug product outside of the immediate pack – Tests on the drug product in the immediate pack – Tests on the drug product in the marketing pack Where appropriate, impact of light during manufacturing 17 | January20-22, 18-21,2010 2012 Satish Mallya January Q1C Annex to Q1A (R2) Additional guidance on line extensions Reduced requirements at time of filing: 6 months accelerated and 6 months long term 18 | January20-22, 18-21,2010 2012 Satish Mallya January Q1D - Bracketing 19 | January20-22, 18-21,2010 2012 Satish Mallya January Q1D - Matrixing 20 | January20-22, 18-21,2010 2012 Satish Mallya January Q1D - Matrixing 21 | January20-22, 18-21,2010 2012 Satish Mallya January Q1E EVALUATION OF STABILITY DATA Provides recommendations for: (at RT, Refrigerated and Freezer storages) – treating stability data – Extending re-test period or shelf-life beyond period covered by long-term data – Statistical approaches to analysis of stability data Progression: – Start with data under accelerated condition – Then assess data under intermediate condition, if appropriate – Finally evaluate trends and variability of the long-term data 22 | January20-22, 18-21,2010 2012 Satish Mallya January Outcomes When there is no significant change under accelerated conditions (RT) Long-term and accelerated data showing little or no change over time and little or no variability Retest period or shelf life can be up to twice, but NMT 12 months beyond the period covered by long-term data Long-term or accelerated data showing change over time and/or variability Data not amenable to statistical analysis, but relevant supporting data provided: Retest period or shelf life can be up to 1.5 times, but NMT 6 months beyond the period covered by long-term data If a statistical analysis is performed: Retest period or shelf life of up to twice, but not more than 12 months beyond the period covered by long-term data 23 | January20-22, 18-21,2010 2012 Satish Mallya January Outcomes When there is significant change under accelerated conditions (RT) but no significant change at intermediate condition: Data not amenable to statistical analysis: Retest period or shelf life can be up to 3 months beyond the period covered by long-term data if backed by relevant documentation If statistical analysis is performed: Retest period or shelf life can be up to 1.5 times, but NMT 6 months beyond the period covered by long-term data when backed by statistical analysis and relevant supporting data 24 | January20-22, 18-21,2010 2012 Satish Mallya January Q2(R1) VALIDATION OF ANALYTICAL PROCEDURES Defines validation characteristics: – Accuracy – Precision • Repeatability • Intermediate Precision – Specificity – Detection Limit – Quantitation Limit – Linearity – Range Robustness to be considered at appropriate stage of development of the analytical method System suitability test parameters to be established for a particular procedure depending on the type of procedure being validated Pharmacopoeias to be consulted for additional information 25 | January20-22, 18-21,2010 2012 Satish Mallya January VALIDATION CHARACTERISTICS Validation characteristics ID Accuracy - Precision - Impurities Assay Quant. limit + - + Repeatibility - + - + Int.Precision + + - + Specificity - + + + LOD - - + - LOQ - + - - Linearity - + - + + - + Range 26 | January20-22, 18-21,2010 2012 Satish Mallya January Q3 Impurities Impurities in New Drug Substances Q3A(R2): Defines thresholds for reporting, identification and qualification of impurities in DS Impurities in New Drug Products Q3B(R2): Defines thresholds for reporting, identification and qualification of impurities in DP Guideline for Residual Solvents Q3C (R5): Classifies residual solvents by risk assessment: – Class 1 solvents: solvents to be avoided – Class 2 solvents: solvents to be limited – Class 3 solvents: solvents with low toxic potential Guideline for Metal Impurities Q3D (Concept paper – July 2009) 27 | January20-22, 18-21,2010 2012 Satish Mallya January Q3A(R2) CLASSIFICATION OF IMPURITIES Organic Impurities – – – – – Starting materials By-products Intermediates Degradation products Reagents, ligands, catalysts Inorganic Impurities – – – – Reagents, ligands, catalysts Heavy metals or other residual metals Inorganic salts Other materials (e.g., filter aids, charcoal) Residual Solvents 28 | January20-22, 18-21,2010 2012 Satish Mallya January Q3A(R2) Definitions Qualification: The process of acquiring and evaluating data that establishes the biological safety of an individual impurity or a given impurity profile at the level(s) specified. Reporting Threshold: A limit above (>) which an impurity should be reported. Specified Impurity: An impurity that is individually listed and limited with a specific acceptance criterion in the new drug substance specification. A specified impurity can be either identified or unidentified. Unidentified Impurity: An impurity for which a structural characterisation has not been achieved and that is defined solely by qualitative analytical properties (e.g., chromatographic retention time) Unspecified impurity: An impurity that is limited by a general acceptance criterion, but not individually listed with its own specific acceptance criterion, in the new drug substance specification 29 | January20-22, 18-21,2010 2012 Satish Mallya January Q3A(R2) 30 | January20-22, 18-21,2010 2012 Satish Mallya January Q3A(R2) 31 | January20-22, 18-21,2010 2012 Satish Mallya January Q3B(R2) 32 | January20-22, 18-21,2010 2012 Satish Mallya January Q3B(R2) 33 | January20-22, 18-21,2010 2012 Satish Mallya January Q3C(R5) Provides 2 options for describing limits of Class 2 Solvents Option 1: As per the table provided - calculated using TDI of 10 g and the calculation – Concentration (ppm) = 1000 x Permitted Daily Exposure (PDE)/ Dose – PDE is given in terms of mg/day and dose is given in g/day. Solvent PDE (mg/day) Acetonitrile 4.1 410 Chlorobenzene 3.6 360 If TDI is more than 10 g use option 2 34 | Concentration limit (ppm) January20-22, 18-21,2010 2012 Satish Mallya January Example for Option 2 Option 2: It is not considered necessary for each component of the drug product to comply with the limits given in Option 1. The PDE in terms of mg/day can be used with the known maximum daily dose and equation (Concentration (ppm) = 1000 x PDE/ Dose) to determine the concentration of residual solvent allowed in drug product Example: PDE of acetonitrile is 4.1mg/day Component exposure Amount in formulation Acetonitrile content Daily Drug substance 0.3 g 800 ppm 0.24 mg Excipient 1 0.9 g 400 ppm 0.36 mg Excipient 2 3.8 g 800 ppm 3.04 mg Drug Product 5.0 g 728 ppm 3.64 mg The sum of the amounts of solvent per day should be less than that given by the PDE. 35 | January20-22, 18-21,2010 2012 Satish Mallya January Q6A Addresses aspects such as: – – – – – – – – – – – 36 | Periodic or skip testing Release vs shelf-life criteria In-process tests Design and development considerations Limited data available at filing Parametric release Alternative procedures Pharmacopoeial tests and acceptance criteria Evolving technologies Impact of drug substance on drug product specifications Reference standard January20-22, 18-21,2010 2012 Satish Mallya January Q6A Decision Trees #1 – Establishing acceptance criteria for specified impurity In DS #2 – Establishing acceptance criteria for degradation product in DP #3 – Establishing acceptance criteria for PSD in DS #4 – Investigating need to set acceptance criteria for polymorphism in DS and DP #5 – Establishing ID, Assay and enantiomeric impurity procedures for chiral DS and chiral DS in DP #6 – Microbiological Quality Attributes of DS and Excipients #7 – Setting acceptance criteria for DP dissolution #8 – Microbiological Quality Attributes of non sterile DP 37 | January20-22, 18-21,2010 2012 Satish Mallya January Periodic or Skip Testing Should be justified. May be applied to certain tests only (e.g. residual solvents and microbiological test for solid oral products) Recommend that it should be applied post approval Batch to batch retesting to be restored in the event of failure 38 | January20-22, 18-21,2010 2012 Satish Mallya January Design and Development Considerations It may be possible to propose excluding or replacing certain tests based on experience and data accumulated: – microbiological testing for drug substances and solid dosage forms which have been shown during development not to support microbial viability or growth (Decision Trees #6 and #8) – extractables from product containers where it has been reproducibly shown that either no extractables are found in the drug product or the levels meet accepted standards for safety 39 | January 18-21 2012 January20-22, 18-21,2010 2012 Satish Mallya January Design and Development Considerations – particle size testing may be performed as an in-process test, or may be performed as a release test, depending on its relevance to product performance – dissolution testing for immediate release solid oral drug products made from highly water soluble drug substances may be replaced by disintegration testing, if these products have been demonstrated during development to have consistently rapid drug release characteristics (Decision Tree #7) (only accepted in exceptional circumstances and all conditions must be met including substantial development data) 40 | January20-22, 18-21,2010 2012 Satish Mallya January 41 | January20-22, 18-21,2010 2012 Satish Mallya January