In “improving quality” we can lose trust!
Professional development for continual evolution and a revolution. “Revolution” embedded in Evolution: In the “real world” mind trumps matter! Legacy can be hard-wired in minds.
Assurance is critical to public health! We must listen to “Canary Tweeting in our Mind”!
1. Leadership for PAT and Industry 4.0
Ajaz S. Hussain, Ph.D.
National Institute for
Pharmaceutical Technology
& Education, Inc
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 1
2. Professional development for
evolution and a revolution
• Background: Lessons in the FDA’s PAT &
CGMP’s for 21st Century Initiatives
• Challenge: Equivalence in Inequality
• Question: Operational, tactical and
strategic considerations?
• Answer: Assurance is as important as
control; to give assurance to others one
must be self-assured.
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 2
3. Experiential
Learning
• USA
• India
• Switzerland
• Europe
• Japan
• Canada
• Mexico & South America
• South Korea
• Middle-east
• Africa
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 3
4. Lessons in the PAT
Initiative
• Perceived “risk” and “fear”
are MAJOR hurdles; we
underestimate its impact
• FDA’s PATRIOT Team
building & certification
• FDA CRADA with Pfizer and
Novartis
• Aventis “Real time release”
approval in 2004
• PAT: Tit for Tat experience
that followed Sau (Larry) Lee March 2017
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 4
5. PAT Implementation: Aventis 2004
RPS/FDA Meeting, London – 14 December, 2004
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 5
6. “Revolution” embedded in Evolution:
In the “real world” mind trumps matter!
CPAC Satellite Meeting Rome, March 25, 2010ISPE Hamburg, 19th of April 2013
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 6
7. The Alternative Plan (larger sample size)
provides a better assurance of quality
than USP: But!
• What is the probability of rejecting a good batch?
(Producer risk)
• What is the probability of releasing a bad batch?
(Consumer risk)
• The USP OC curve shows 90% probability of passing a
batch with 2% product outside 85-115% of Label Claim
• The Alternative Plan OC curve shows 0% probability of
passing a batch with 2% outside 85-115% of Label
Claim
• Legacy challenges and fear of OOSGraham D. Cook. CPAC Satellite Meeting Rome,
March 25, 2010
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 7
12. Assurance critical to public health!
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 12
13. We must listen to “Canary Tweeting in our Mind”!
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 13
14. In “improving
quality” we
can lose trust!
• Joint position statement of European Thyroid Association and Thyroid
Federation International. European Thyroid Journal. 2018;7(5):1-5.
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 14
15. Value information about a drug (such as the price tag)
can strongly affect its therapeutic effect
Science. Vol. 358, Issue 6359, pp. 105-108. 06 Oct 2017
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 15
16. Summary so far: A canary
tweeting in my mind
• Lessons in PAT: Legacy challenges and perceived
“risk” and “fear” are MAJOR hurdles; we
underestimate its impact
• Assurance critical to public health! The on-going
levothyroxine multinational saga reminds us that in
“improving quality” we can lose trust!
• We are on a journey, as FDA reminds us, to achieve a
“One Quality Voice” within the sector
• We must recognize the “real world” challenges of
“Equivalence in Inequivalence” as an “Ontological
Conflict”
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 16
17. Question: Operational, tactical and strategic considerations?
Workshop on Process Analytical Technologies for Biologicals 15th March 2007, Room 3A, EMA
Fisher, Shewhart, Deming…. What else?
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 17
18. Fisher, Shewhart, Deming…. What else?
For additional information visit:
https://www.slideshare.net/a2zpharmsci
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 18
19. To err is human, professional development via
design & systems thinking
Why metamorphosis to meaningful experience necessary!
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 19
20. Where ontological conflicts exists attention to representational
practices and epistemology, however important, are insufficient.
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 20
25. NIPTE Creating Experiential Learning Opportunities for
Continuing Education with Professional Development
• Personalized continual development while
utilizing principles and know-how in ICH Q8 -
11 and FDA’s Process Validation 2011
• Identifying legacy blind-spots, problem-
solving and optimal science-technology-
behavior integration across product life cycle
to reduce regulatory uncertainty
• Self-authorship a path to self-assurance; e.g.,
improving quality of Development Reports
and QOS (to prevent CRL) and effective
investigations and CAPA to build an effective
pQMS (to prevent Warning Letters)
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 25
26. NIPTE’s NPK: Ability to
measure demands
responsibility to explain
• To publish in AAPS PharmSci Tech.
• Open Access, please download
The paradoxical combination of “new”
and “prior knowledge” is intended to
distinguish NPK from traditional and
proprietary pharmaceutical “prior
knowledge.” Critically, it is also intended
to draw attention to the paradoxical
state of collective inattention to the
root cause of challenges to the
availability of affordable medicines with
a high assurance of quality.
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 26
27. Summary
• Lessons in PAT: Legacy challenges
and perceived “risk” and “fear”
are MAJOR hurdles; consequence
of underestimating its impact is
significant
• Assurance is critical to public
health! The levothyroxine
multinational saga is a canary
reminding us that in “improving
quality” we can lose trust!
• We are on a journey, as FDA
reminds us, to achieve a “One
Quality Voice” within the sector
• We must recognize the
“information asymmetry in real
world an “Ontological Conflict” to
be prepared to address the
challenge of “Equivalence in
Inequivalence”
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 27
28. Summary (contd.)
• QbD, effective investigations to
system wide CAPA, continual
improvement and Industry 4.0
demands higher Orders of
Consciousness
• We must build a cadre of leaders
who can deliver “Equivalence in
Inequality”
• Personalized-PD is self-authorship
in the interest of patients at every
level; individual, corporate and
sector level (e.g., consensus stds.)
• Self-authorship in the interest of
patients can be the “butterfly
effect” we need to evolve with
care the revolution called Industry
4.0 or SmartFactory
• NIPTE stands ready to support the
sector achieve “One Quality
Voice” and reduce “understanding
asymmetry” in the real world!
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 28
29. Vision 2020:
I can see
more clearly
now!
We cannot and must not ignore the “root cause”, it is us!
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 29
30. For additional
information on
NIPTE programs
• Please e-mail me at Ajaz@nipte.org
or Vadim J. Gurvich at
vadimg@nipte.org
3/4/2019 (C) Ajaz S. Hussain, Ph.D. IFPAC 2019 Maryland USA 30