Pharmaceutical Development Training Workshop on Pharmaceutical Development with focus on Paediatric Formulations Protea Hotel Victoria Junction, Waterfront Cape Town, South Africa Date: 16 to 20 April 2007 Slide 1 April 2007 Regulatory Aspects of Pharmaceutical Product Development and the Need for Registration Prior to Marketing Presenter: Joy van Oudtshoorn Industrial Pharmacy Section International Pharmaceutical Federation (FIP) +27 12 347 1392; +27 83 460 5534; joyvo@icon.co.za Executive Director: Scientific and Medical Affairs, J & B Pharmaceutical Consultants Slide 2 April 2007 Outline Slide 3 April 2007 Slide 4 April 2007 Outline Need for registration prior to marketing Guidelines CTD Pharmaceutical Development Regulatory points to consider Summary and Conclusions Slide 5 April 2007 Need for registration prior to marketing Approve medicines based on quality, safety and efficacy and the ability to subsequently adhere to these As result of e.g. – Diethylene glycol USA 1930s lacquer, cosmetics, anti-freeze, lubricants, softening agent, lubricant - preparation of sulfanilamide 105/353 deaths - 1938 Food Drug and Cosmetic Act < seize mislabelled and adulterated products – Thalidomide late 50s early 60s hypnotic, sedative, ‘non-toxic’ teratognic – “Mishaps” actives, excipients, manufacturing, packaging, distribution and storage – Counterfeit and fraud Slide 6 April 2007 Guidelines – – – – – – Slide 7 April 2007 CTD Q8 Q6A and Q6B Q9 Country specific guidelines WHO TRS 937 Annexes 7 and 8 CTD Overall Table of Contents (ToC) 2.1 ToC of the CTD (Mod 2,3,4,5) Module 1 1.1 ToC of Module 1 or overall ToC, including Module 1 2.1 2.2 Module 2 2.4 2.5 2.3 2.6 Module 3 3.1 ToC for Module 3 Slide 8 April 2007 Module 4 4.1 ToC for Module 4 2.7 Module 5 5.1 ToC for Module 5 Implementation Coordination Group June 2002 CTD Numbering System Module 1 Module 2 1.0 Regional Administrative Information 1.1 ToC of Module 1 or overall ToC, including Module 1 1.0 2.1 ToC of the CTD (Mod 2,3,4,5) 2.1 2.2 Introduction 2.2 2.3 Quality Overall Summary 2.4 Nonclinical Overview 2.4 2.5 2.3 2.6 Module 3 Quality Slide 9 April 2007 Module 4 Nonclinical Study Reports 2.5 Clinical Overview 2.7 2.6 Nonclinical Written and Tabulated Summaries Module 5 2.7 Clinical Summary Clinical Study Reports Implementation Coordination Group June 2002 Pharmaceutical Development : Q8 guideline – Objective to describe the suggested contents and provide guidance of the Pharmaceutical Development in ICH CTD format – Indicates where demonstration of greater understanding of pharmaceutical and manufacturing sciences can create a basis for flexible regulatory approaches, degree of which is predicated on level of relevant scientific knowledge gained – Applicable to products defined in module 3, possibly also others, not applicable during clinical research stages of development Slide 10 April 2007 Pharmaceutical Development Section of CTD: Q8 Guideline – opportunity to provide comprehensive understanding of the product and its manufacturing process for reviewers and inspectors and also for company personnel – should describe the knowledge that establishes the dosage form and formulation suitable for the intended use – should include sufficient information to provide an understanding of the development of the product and its manufacturing process – determine aspects critical to product quality – justify control strategies Slide 11 April 2007 Pharmaceutical Development Section of CTD continued – including an expanded design space and demonstrating an enhanced knowledge of product performance over range of attributes, options and parameters could facilitate • risk-based regulatory decisions • manufacturing process improvements without further regulatory review • reduction of post approval submissions • real-time quality control leading to reduction of end-product release testing – Level of knowledge, not volume of data provides basis for science based submissions Slide 12 April 2007 Pharmaceutical Development Purpose and Scope Aim: to design a quality product and manufacturing process to consistently deliver the intended performance of the product Knowledge gained: – provides scientific understanding to establish design space, specifications and manufacturing controls – basis for quality risk management - quality built in by design – from changes in formulation and processes during development and life-cycle management, and prior information Slide 13 April 2007 Q8 Aspects to consider Innovator or multisource finished pharmaceutical product Product components – Active substance (physicochemical and biological properties, equivalence of different sources) – Excipients (characteristics and concentration that can influence drug performance, compatibility with active and each other) Slide 14 April 2007 Q8 Aspects to consider continued HPLC profiles of trimethoprim from different manufacturers of China (A, B) Israel (C) USA (D, E) Impurities, any of – products of incomplete reaction – products of over reaction – impurities in starting materials – impurities from the solvents of the reaction – impurities from catalysts – products of side reactions – degradation products – residual solvents – enantiomeric impurities – inorganic impurities – impurities in excipients – polymorphs as impurities R Nageswara Rao, V.Nagaraju J.Pharm. Biomed.Anal. 33 (2003) 335 -377 Slide 15 April 2007 Q8 Aspects to consider continued Dosage form, finished pharmaceutical product Appropriate paediatric dosage forms for long term / chronic administration – Injections, syrups, suspensions, solutions, tablets, capsules ? • Aspects to consider: taste, sugar, colourant, flavours or preservative content, mass and breakages transport, logistics o/s ttt regimen products – Formulation development – Overages – Physicochemical and biological properties Slide 16 April 2007 Q8 Aspects to consider continued Manufacturing Process Development selection, control, any improvements of the process, critical attributes, process options, appropriateness of equipment, process validation, process control requirements, product specifications, ability of process to reliably produce quality product under different operating systems Container Closure System choice and rationale for selection Microbiological Attributes choice and rationale for selection Compatibility of product, labelling information with constitution diluents, admixtures or dilution prior to administration (precipitation and stability) Slide 17 April 2007 Glossary Continuous Process Verification: An alternative approach to process validation in which manufacturing process performance is continuously monitored and evaluated Design Space: The multidimensional combination and interaction of input variables (e.g. material attributes) and process parameters that have been demonstrated to proved 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 Slide 18 April 2007 Glossary continued Formal Experimental Design: A structured organised method for determining the relationship between factors affecting a process and the output of that process. “Design of experiments” Process Analytical Technology (PAT): A system for designing, analysing 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 en ensuring final product quality Process Robustness: Ability of a process to tolerate variability of materials and changes of the process and equipment without negative impact on quality Slide 19 April 2007 Quality Risk Management (QRM) Q9 Introduction Scope Principles of Quality Risk management General Quality Risk Management Process Risk Management Methodology – Annex I Risk Management Methods and Tools Integration of QRM process into Industry and Regulatory operations – Annex II Definitions References Slide 20 April 2007 Potential Applications for QRM Quality Risk Management (QRM) Q9 continued Q9 Guideline Risk : the combination of the probability of occurrence of harm and the severity of that harm Guideline provides principles and examples of tools for QRM Principles of Quality Risk management – The evaluation of risk to quality should be based on scientific knowledge and ultimately link to the protection of the patient – the level of effort, formality and documentation of the QRM process should be commensurate with the level of risk Slide 21 April 2007 Q9 Guideline continued General Quality Risk Management Process – Risk Assessment • identification - what might go wrong • analysis - what is the likelihood and what are the consequences (severity) • evaluation - comparison of the identified and analysed risk against given criteria – Risk Control • reduction • acceptance – Risk Communication – Risk Review • review events Slide 22 April 2007 General Quality Risk Management Process continued Initiate Quality Risk Management Process Risk Assessment Risk Identification Risk Analysis Risk Evaluation Ri s k Com munic ation Risk Control Risk Reduction Risk Acceptance Ri sk Ma nage ment t ools unacceptable Initiate Quality Risk Management Process Output / Result of the Quality Risk Management Process Risk Assessment Risk Identification Risk Analysis Risk Review unacceptable Risk Control Risk Reduction Risk Acceptance Output / Result of the Quality Risk Management Process Review Events Slide 23 April 2007 Risk Review Review Events R i s k M a n a g e m e nt t o ol s Ri s k C o m m u ni c a t i o n Risk Evaluation Risk Management Methodology Annex I Risk Management Methods and Tools – Basic Methods [flowcharts, check sheets process mapping, cause & effect diagrams (fishbone diagram)] – Failure Mode Effects Analysis (FMEA) – Failure Mode, Effects and Criticality Analysis (FMECA) – Fault Tree Analysis (FTA) – Hazard Analysis and Critical Control Points (HACCP) – Hazard Operability Analysis (HAZOP) – Preliminary Hazard Analysis (PHA) – Risk Ranking and Filtering – Supporting Statistical Tools Slide 24 April 2007 Simple explanations of some tools Failure Mode Effects Analysis (FMEA) – Break down large complex processes into manageable steps Failure Mode, Effects and Criticality Analysis (FMECA) – FMEA & links severity, probability & detectability to criticality Fault Tree Analysis (FTA) – Tree of failure modes combinations with logical operators Hazard Analysis and Critical Control Points (HACCP) – Systematic, proactive, and preventive method on criticality Hazard Operability Analysis (HAZOP) – Brainstorming technique Slide 25 April 2007 Initiate Quality Risk Management Process Risk Assessment Risk Identification Risk Analysis Ri s k C o m m u ni c a t i o n Risk Evaluation unacceptable Risk Control Risk Reduction Risk Acceptance Output / Result of the Quality Risk Management Process Risk Review Review Events R i s k M a n a g e m e nt t o ol s Preliminary Hazard Analysis (PHA) – Possibilities that the risk event happens Risk ranking and filtering – Compare and prioritize risks with factors for each risk Q9 Guideline continued Integration of QRM process into Industry and Regulatory operations Annex II Potential Applications for QRM Integrated Quality Management, Regulatory Operations, Development, Facilities, Equipment and Utilities, Materials Management, Production, Laboratory Control and Stability Studies, Packaging and Labelling, Frequently Asked Questions (Q&A) Definitions References Slide 26 April 2007 Basic risk management facilitation methods Cause and Effect Diagrams (Ishikawa / fish bone) Environment People Materials Problem statement Equipment Measurement System Methods Prepare by members of ICH Q9 EWG of example only July 2006 Slide 27 April 2007 Basic risk management facilitation methods continued Cause and Effect Diagrams (Ishikawa / fish bone) To associate multiple possible causes with a single effect Constructed to identify and organize possible causes for it Primary branch: represents the effect Major branch: corresponds to a major cause Minor branch: correspond to more detailed causal factors Prepare by members of ICH Q9 EWG of example only July 2006 Slide 28 April 2007 Basic risk management facilitation methods Cause and Effect Diagrams (Ishikawa / fish bone)continued How to perform? Define and agree a precise problem statement (put as “head” of fish bone) Think “What could be its causes?” for each node Add it to the “fish bone” diagram For each line pursue back to its root cause Consider splitting up overcrowded sections “bones” Environment People Materials Consider which potential root causes and the need for further investigation on them Problem statement Equipment Prepare by members of ICH Q9 EWG of example only July 2006 Slide 29 April 2007 Measurement System Methods Basic risk management facilitation methods Cause and Effect Diagrams (Ishikawa / fish bone) continued Basic risk management facilitation methods Cause and Effect Diagrams (Ishikawa / fish bone) C. Kingery, The Six Sigma Memory Jogger II Slide 30 April 2007 Cause and Effect Diagram for Tablet Hardness Coating Drying Milling Analytical Temperature Spray Rate Redrying Pan Speed Time Milling Gun Distance Temp RH Temperature Screen Size Air Flow Atomizing Air Pressure Mill Speed Precompressing Operator Training Spray Rate HPMC Punch Penetration Depth Spray Pattern Tooling Plant Factors P.S. Process Conditions LOD Temp Press Speed P.S. Feed Frame Scrape Down Compressing Chopper Speed Mixer Speed Methoxyl Hydroxyl P.S. LOD Other Syloid Lactose Endpoint Coating Power Time Slide 31 April 2007 Tablet Hardness Age Binder Feeder Speed Method Drug Substance Water Main Compressing Temp/RH Sampling Porosity Shock Cycle Operator Other Granulation Raw Materials © Alastair Coupe, Pfizer Inc. Regulatory Points to Consider Reference product(s) FDA strongly recommends that sponsors use the U.S.-approved drug as the reference drug in BE studies to support FDA approval of a new drug product. If the applicant has right of reference to information that shows that the brand name products in the United States and Europe are equivalent formulations, then a 505(b)(2) application could be approved based in part on a BE study conducted comparing the new product with the European approved product. The potential use of BE studies comparing a test drug with a European reference should be discussed with FDA in advance of any submission.1 EU Test products in an application for a generic product are normally compared with the corresponding dosage form of an innovator medicinal product (reference product). … When variations to an essentially similar product are made the reference product for the bioequivalence study should be the innovator product.2 WHO The comparator product is a pharmaceutical product with which the multisource product is intended to be interchangeable in clinical practice. The comparator product will normally be the innovator product for which efficacy, safety and quality have been established. The selection of the comparator product is usually made at the national level by the drug regulatory authority.3 Slide 32 April 2007 Regulatory Points to Consider Data – Appropriateness, compliance – Optimal use, design space concept – Assess the need for additional studies (e.g. bioequivalence, stability) relating to scale up and technology transfer – Presentation – Inspection/audit Slide 33 April 2007 Summary and Conclusions Need for the registration of medicines Comprehensive guidelines Common interest, the Patient 1 2 3 Slide 34 FDA Guidance for Industry Fixed Dose Combinations, Co-Packaged Drug Products, and Single-Entity Versions of Previously Approved Antiretrovirals for the Treatment of HIV" October 2006 EU CPMP/EWP/QWP/1401/98: Investigation of Bioavailability and Bioequivalence, 26-Jul-2001 WHO TRS 937 Annex 7, 8 April 2007 Slide 35 April 2007