Pharmaceutical Product Quality, Quality by Design, cgmp, and Quality Metrics



Similar documents
Risk Based Pre-Approval Inspection

Quality by Design Approaches to Analytical Methods -- FDA Perspective. Yubing Tang, Ph.D. FDA/CDER/ONDQA AAPS, Washington DC October 25, 2011

OFFICE OF PHARMACEUTICAL QUALITY FDA

ICH Q10 - Pharmaceutical Quality System

Application of Quality Risk Management to Pharmaceutical Operations. Eldon Henson, Vice President, Quality Operations

Quality Metrics An FDA Perspective PDA Dinner and Dialogue. Melissa Seymour VP, Corporate Quality DRAFT

Request for Quality Metrics Guidance for Industry

Product Quality Management

Post-Approval Change Management: Challenges and Opportunities An FDA Perspective

[ABOUT THE AUTHOR. FDA Lifecycle Approach to Process Validation What, Why, and How? PQ Forum. Paul L. Pluta]

Guidance for Industry Quality Systems Approach to Pharmaceutical CGMP Regulations

An FDA Perspective on Post- Approval Change Management for PAT and RTRT

Library Guide: Pharmaceutical GMPs

QUALITY BY DESIGN (QBD) : A COMPLETE REVIEW

Regulatory Expectations of Executive Management

Process Validation: Practical Aspects of the New FDA Guidance

Guidance for Industry

Quality by Design (QbD) Overview

Moving from Quality Control to Quality Assurance (Proactive Compliance!)

Preparing for an FDA Pre-Approval Inspection (PAI)

ICH Public Meeting. Joseph C. Famulare. October 2, Acting Deputy Director Office of Compliance CDER / FDA Office of Compliance

Pharmaceutical Quality Systems: US Perspective

Guidance for Industry

Preparing for the Pre-Approval Inspection What to do Before the FDA Arrives. Barry A. Friedman, Ph.D. Consultant

Guidance for Industry. Q10 Pharmaceutical Quality System

QUALITY RISK MANAGEMENT (QRM): A REVIEW

Commercial Manufacturing - Qualification & Validation-related GMP Deficiencies and Other Lifecycle Considerations

FOOD AND DRUG LAW JOURNAL Analyzing the Laws, Regulations, and Policies Affecting FDA-Regulated Products

Workshop B Control Strategy

Guidance for Industry

QbD Considerations for Analytical Methods - FDA Perspective

Implementing Lifecycle Validation Practices at Contract Manufacturing Organizations

IVD Regulation Overview. Requirements to Assure Quality & Effectiveness

Topic 3 RISK MANAGEMENT APPROACH for CMC SUBMISSIONS AND REVIEW. Topic Leaders Kim Huynh-Ba, Pharmalytik Lynn Gold, Camargo

Lifecycle Management of Analytical Procedures; What is it all about? Jane Weitzel Independent Consultant

ICH guideline Q8, Q9 and Q10 - questions and answers volume 4

Quality Agreement. by and between. Supplier Name. Address: and. Client Name: Address:

Best Practices in Statistical Process Monitoring of Biopharmaceutical Manufacturing Operations

Guidance for Industry PAT A Framework for Innovative Pharmaceutical Development, Manufacturing, and Quality Assurance

Sandoz Private Limited 10/22/15

COMPLIANCE BY DESIGN FOR PHARMACEUTICAL QUALITY CONTROL LABORATORIES INSIGHT FROM FDA WARNING LETTERS

Risk-Based Change Management Using QbD Principles

FOOD AND DRUG ADMINISTRATION COMPLIANCE PROGRAM GUIDANCE MANUAL

Guidance for Industry ANDAs: Stability Testing of Drug Substances and Products

BUILDING QUALITY INTO CLINICAL TRIALS AN FDA PERSPECTIVE

Guidance for Industry

What is Process Validation?

What to control? CQAs and CPPs

PROPOSAL FOR REVISION OF THE SUPPLEMENTARY GUIDELINES ON GOOD MANUFACTURING PRACTICES: VALIDATION, APPENDIX 7: NON-STERILE PROCESS VALIDATION

Workshop on process validation

The Product Review Life Cycle A Brief Overview

1

Combination Products. Presented by: Karen S. Ginsbury For: IFF March PCI Pharma

On-Site GMP Training GMP COMPLIANCE TECHNICAL

Annex 7 Guidelines on pre-approval inspections

Let s skip over the next ten

The FDA recently announced a significant

Pharmaceutical Quality & Clinical Research Quality: The Interaction

Auditing as a Component of a Pharmaceutical Quality System

PHARMACEUTICAL QUALITY SYSTEM Q10

Quality Risk Management Principles and Industry Case Studies

Measuring Pharmaceutical Quality through Manufacturing Metrics and Risk-Based Assessment May 1 & 2, 2014

Guidance for Industry

International GMP Requirements for Quality Control Laboratories and Recomendations for Implementation

ICH Q10 Pharmaceutical Quality System (PQS)

BIOTECHNOLOGY OPERATIONS

Regulatory Submission: Applying GLP in Surgical Efficacy Studies

Quality Risk Management The Pharmaceutical Experience Ann O Mahony Quality Assurance Specialist Pfizer Biotech Grange Castle

CLINICAL DATA MONITORING PLAN (CDMoP) PROTOCOL # [0000] [TITLE]

Diogo Filipe Lopes Ferreira

Harmonizing Change Control Processes Globally

Guidance for Industry Pyrogen and Endotoxins Testing: Questions and Answers

Overview of Pre-Approval Inspections

Title:: Effective GMP AUDITS for APIs and Formulation Pharma Companies By G.Sundar-Director/Consultant PharmQA Compliance solutions

Welcome Computer System Validation Training Delivered to FDA. ISPE Boston Area Chapter February 20, 2014

The purpose of this Supplier Quality Standard is to communicate the expectations and requirements of Baxter Healthcare Corporation to its suppliers.

Annex 2. WHO guidelines on quality risk management. 1. Introduction Glossary Quality risk management process 70

IBM asset management solutions White paper. Managing corrective and preventive action (CAPA) in a life sciences environment.

Guidance for Industry

First In Human Pediatric Trials and Safety Assessment for Rare and Orphan Diseases

Quality by Design Concept

TRAINING TITLE: CAPA System Overview for Managers (WORK-021)

Addressing Risk in Partner / Contractor Selection and Onboarding. Michael Davidson VP Quality Systems and Compliance March 2014

ICH Q10 and Change Management: Enabling Quality Improvement

What is the correct title of this publication? What is the current status of understanding and implementation?

Pharmaceutical Quality Management System: Current Concept

Innovation and Continuous Improvement in Pharmaceutical Manufacturing

Guidance for Industry Tablet Scoring: Nomenclature, Labeling, and Data for Evaluation

Health Research Institute. Major shift ahead in how FDA regulates drug quality

ICH Q9 Quality Risk Management - an industry view. Peter H. Gough, Eli Lilly and Company

GOOD DOCUMENTATION AND QUALITY MANAGEMENT PRINCIPLES. Vimal Sachdeva Technical Officer (Inspector), WHO Prequalification of Medicines Programme

Engineering for the new pharma reality

PPG SUPPLIER DEVELOPMENT ASSESSMENT

LIBRARY GUIDE. Online Courses. March 2012

Quality Management System (QMS) for Active Pharmaceutical Ingredients (API) Manufacturers

Comparison between FDA QSR and ISO 13485

Engineering Nanomedical Systems

Lifecycle Management of Analytical Procedures: Method Development, Procedure Performance Qualification, and Procedure Performance Verification a

Comparative analysis between the possible regulatory approaches to GMP compliance TITOLO PRESENTAZIONE

ASTRAZENECA GLOBAL POLICY QUALITY AND REGULATORY COMPLIANCE

Transcription:

Pharmaceutical Product Quality, Quality by Design, cgmp, and Quality Metrics Lawrence X. Yu, Ph.D. Deputy Director Office of Pharmaceutical Quality Center for Drug Evaluation and Research Food and Drug Administration 1

What is Pharmaceutical Quality? Janet Woodcock A high quality drug product as a product free of contamination and reproducibly delivering the therapeutic benefit promised in the label Free of contamination: CGMP focus Reproducibly delivering the therapeutic benefit promised in the label: QbD focus Therefore, Pharmaceutical Quality = QbD + CGMP? 2

What is Quality by Design (QbD)? A systematic approachto development that begins with predefined objectivesand emphasizes product and process understanding and process control, based on sound science and quality risk management Predefined objectives Product and process understanding Process control Sound science Quality risk management Systematic approach Define Quality Target Product Profile (QTPP) Identify Critical Quality Attributes (CQA) Identify critical material attributes (CMA) and critical process parameters (CPP) Understand the relationship between CMA/CPP and CQA Establish appropriate Control Strategy, including justifications Science-driven development (scientific literature, prior knowledge, DOEs etc.) Risk-based development (ICH Q9) 3

Labeled Use Safety and Efficacy Overview of QbD DEFINE Quality Target Product Profile Product Design and Understanding Process Design and Understanding Control Strategy L. X. Yu. Pharm. Res. 25:781-791 (2008) TARGET DESIGN and UNDERSTANDING Continual Improvement IMPLEMENTATION 4

5

Quality by Testing vs. Quality by Design Quality by Testing Specification acceptance criteria are based on one or more batch data Testing must be made to release batches Quality by Design Specification acceptance criteria are based on performance Testing may not be necessary to release batches L. X. Yu. Pharm. Res. 25:781-791 (2008) 6

7

Pharmaceutical QbD Objectives Achieve meaningful product quality specifications that are based on assuring clinical performance Increase process capability and reduce product variability and defects by enhancing product and process design, understanding, and control Increase product development and manufacturing efficiencies Enhance root cause analysis and post-approval change management L. X. Yu et al. AAPS J. 16:771-83 (2014) 8

What are CGMPs? CGMP refers to the Current Good Manufacturing Practice regulations... CGMPs provide for systems that assure proper design, monitoring, and control of manufacturing processes and facilities... This includes establishing strong quality management systems, obtaining appropriate quality raw materials, establishing robust operating procedures, detecting and investigating product quality deviations, and maintaining reliable testing laboratories. This formal system of controls at a pharmaceutical company, if adequately put into practice, helps to prevent instances of contamination, mix-ups, deviations, failures, and errors. 9

CGMP: New Inspection Protocol Project Goal: To develop a new paradigm for inspections and reports that will advance pharmaceutical quality Standardized approach to inspection Data gathering to inform quality intelligence of sites and products Risk based and rule based process, using expert questions Semi-quantitative scoring to allow for comparisons within and between sites More common inspection report structure Recognize and reward positive behaviors in cases where facilities exceed basic compliance 10

NIPP Project Organization New Inspection Protocols Project (NIPP) CDER and ORA Pre-Approval Inspection Subgroup Surveillance Inspection Subgroup For Cause Inspection Subgroup Draft Protocol Observations to inform premarket review decisions Draft Protocol Observations on state of quality in a facility to assess quality risk Evidence of cgmp violations to support enforcement Escalation/ transition to For Cause when conditions indicate 11 11

Quality Metrics Vision A more rigorous and comprehensive approach to quality surveillance that allows for improved monitoring of current status across the inventory of FDA-regulated drug products and manufacturing sites Goals: Objective measures Quality of a drug product Quality of a site Effectiveness of systems associated with the manufacture of pharmaceutical products Draft Guidance published July 27, 2015 http://www.fda.gov/downloads/drugs/guidancecomplianceregu latoryinformation/guidances/ucm455957.pdf 12

FDA Draft Quality Metrics Guidance, July, 2015 Metrics FDA Intends to Calculate Lot acceptance rate Product quality complaint rate Invalidated Out-of-Specification rate Annual product review or product quality review on time rate 13

FDA Draft Quality Metrics Guidance, July, 2015 (continued) Optional Metrics Quality Culture Senior management engagement corrective action and preventive action effectiveness percentage of your corrective actions involved re-training of personnel Process Capability/Performance Process capability is a leading, useful indicator. However, its calculation is relative complex 14

Concept of Process Capability/Performance First introduced in Statistical Quality Control Handbookby the Western Electric Company (1956). process capability is defined as the natural or undisturbed performance after extraneous influences are eliminated. This is determined by plotting data on a control chart. ISO, AIAG, ASQ, ASTM.. published their guideline or manual on process capability index calculation 15

Nomenclature Four indices: C p : process capability index C pk : minimum process capability index P p : process performance index P pk : minimum process performance index ASTM E2281: Standard Practice for Process and Measurement Capability Indices 16

Difference between C pk and P pk Cpk represents the potential process capability (i.e. how well a given process could performwhen all special causes have been eliminated). Ppk addresses how the process has performed without the demonstration of the process to be stable. Forecast future batch failure rate Cpk (Yes); Ppk (No) 17

Yu et al. Use Process Capability to Ensure Product Quality. Pharm. Eng. (2015) In this paper, we introduce the definition and calculation of process capability, illustrate their uses in pharmaceutical industry, and describe the relationship of process capability with production batch failure rate. We also describe the use of process capability in product development, process scale up and qualification, and commercial production. 18

Summary Process capability is a leading, useful indicator. However, its calculation is relative complicated Promise: Quality standard is clinically relevant and a surrogate of clinical performance, then Pharmaceutical Quality = QbD + CGMP?? Ppk = Cpk + CGMP??? 19