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Process Validation of Legacy Products
1. This presentation is compiled by “ Drug Regulations” a
non profit organization which provides free online
resource to the Pharmaceutical Professional.
Visit http://www.drugregulations.org for latest
information from the world of Pharmaceuticals.
3/31/2016 1
2. This presentation is compiled from freely
available resources like the websites of FDA,
EMA, WHO and ISPE.
This presentation is based on a discussion paper
published by ISPE titled “ Process validation Life
cycle implication for legacy products”
“Drug Regulations” is a non profit organization
which provides free online resource to the
Pharmaceutical Professional.
Visit http://www.drugregulations.org for latest
information from the world of Pharmaceuticals.
3/31/2016 2
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3. ◦ This presentation
Examines challenges related to the implementation of
PV Lifecycle concept to legacy products.
Identifies common issues related to the appliation of
Life cycle concept
Discusses potenial reposnes to various scenarios
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4. ◦ Following topics will be discussed and presneted
Current validation Lifecycle expectation for legacy
products
Strategies for assessing and prioritizing requirements
for legacy products
Expectation for revalidating a modified legacy product
Expectation for revalidating an unmodifed legacy
process based on exisitng PV gaps
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5. The concepts in this presentation are based on following
assumptions
◦ Legacy products were previously validated.
◦ These products are currently marketed
◦ Are typically in life cycle stage
Ongoing Process Verification ( OPV)
Also known as Continued Process verification ( CPV)
Original process was validated meeting the predicate rule
requirements
A Pharmaceutical Quality System is in place.
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6. Active Pharmaceutical Ingredients
Drug Products
Large and small molecules
All routes of synthesis and dosage forms
Principles used and applied comply with
understood and accepted International GMP’s
Third party manufacturers and Contract
Manufacturing
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7. Concepts and Principles focus on
◦ Establishing a validated state
◦ Maintaining a validated state
Organizational Strategies will be based on
◦ Product Risk
Dosage form , criticality of clinical effect
◦ Product History
Available data , Quality History, Manufacturing Experience
◦ Prioritization of products requiring remediation
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8. This presentation will not discuss the new
Lifecycle approach per se.
For this the reader can refer our earlier
presentations on this topic
◦ Process Validation: FDA & EU Requirements: (Click here for presentation)
◦ Process Performance Qualification. ( Click here for presentation)
◦ Continued Process Verification ( click here for presentation)
◦ New EU requirements for Qualification & Validation ( Click here for presentation
)
◦ WHO guidance on validation of Non sterile Pharmaceuticals ( Click here for
presentation)
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9. Updated process validation guidance of FDA ,
EMA and WHO discusses 3 phase validation
This is based on Process knowledge and
Quality Risk Management
Aligned with principles of ICH Q 8, Q 9 and Q
10.
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10. Lifecycle Stages
Process Design :
◦ The commercial manufacturing process is defined during this stage based on
knowledge gained through development and scale up activites
Process Qualification
◦ The process design is evaluated if the process along with supporting equipment and
facility is capable of reproducible commercial manufacturing.
◦ This includes manufacture of initial validation lots- Process performance qualification
Ongoing Process Verification:
◦ Post commercial phase
◦ Ongoing assurance during routine production that the process remains in a sate of
control
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11. Ongoing Process Verification:
◦ Is a two phase stage
◦ Initial monitoring of new or redesigned products
Less historical data or process experience
Monitored more intensely
◦ Reduced level monitoring as statistical confidence builds
up.
Initial Phase called as Enhanced OPV
Routine OPV
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12. Prioritization of perceived gaps should preclude remediation
In some cases comprehensive assessment of product may be
available
◦ Annual Product review
◦ Past site inspection readiness efforts
◦ Recent audits
These assessments may be used to support GAP/ Risk
assessment
Output from these assessment should formally be documented
as supporting documentation
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13. The principles used in the approach
presented here will conform to general Risk
Assessment principles
◦ Evaluation of risk to quality should be
Based on scientific knowledge
Ultimately link to the protection of patient
◦ The level of effort , formality and documentation
should be commensurate with level of risk.
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14. Flow chart in next figure ( Fig 1) depicts a two
part decision tree
Top of the chart illustrates original evaluation
This is followed by process specific
evaluation
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18. Evaluate current validated state of each
product
Evaluation should be based on the ability to
demonstrate a state of process control at any
time.
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19. The validated state of each commercial
process depends on following factors:
◦ Ongoing monitoring programme ( OPV) which
monitors appropriate attributes & variables
Provides data to demonstrate ongoing process control
◦ Timely review of OPV to assure control with actions
& adjustments as indicated by quality signal
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20. The validated state of each commercial process
depends on following factors:
◦ Sufficient documented process knowledge
Critical Quality Attributes
Critical Process Parameters
Development reports
Process justification studies
Technical analysis
Process experience
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21. The validated state of each commercial
process depends on following factors:
◦ Sufficient documented process knowledge
This should provide
Adequate rationale for changes to process , investigation
of non conformances,
Maintain adequate control
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22. The validated state of each commercial
process depends on following factors:
◦ Effective Change Management
Is it in place since original or most recent revalidation
Does PV documentation reflect current process
◦ Does P V documentation meet GMP and regulatory
requirements effective at the time of PV
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23. Based on this assessment there can be two
scenarios
1. Quality system indicates positive answers for above
questions
This indicates that product validation life cycle is in place
Routine monitoring can continue by adjusting levels of
sampling and testing indicated by events and trends over
time.
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24. Based on this assessment there can be two
scenarios
2. Quality system indicates GAPS in procedures ,
requirements for one or more products
Indicates need for remediation
Additional actions before implementing OPV
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25. Before implementation of the PV Life cycle
remediation plan ensure that
◦ Quality System Infrastructure is in place
◦ Quality work culture is in place
◦ Support for documentation, training and other
quality systems is in place
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26. Some of the items for consideration for
evaluation of legacy products for compliance
adequacy are given in Table 1in next slides
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31. Expectation of Quality System Management (
QMS) Include
◦ Set requirements for Life Cycle
◦ Allow flexibility to operate in multiple global
markets
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32. Expectation of Quality System Management (
QMS) Include
Standard Operating Procedures
◦ Technical Product ownership & product expertise
◦ Statistical requirements
◦ Data handling and review
◦ Quality Oversight & Management Review
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33. Expectation of Quality System Management (
QMS) Include
Site procedures , validation plans and Quality
systems like Deviation management, change
control periodic product review may require
updating to include lifecycle approach
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34. Expectation of Quality System Management (
QMS) Include
Automated systems for data trending
especially for high product volumes
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35. Prepare detailed site specific plans once
polices and procedures are updated
The implementation of Lifecycle approach can
be a multi phase multi year approach
Plan should be developed to bridge the gap
between current and desired state
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36. The plan should include
◦ Schedule for implementation
◦ Prioritization of products based on
Volume of product in the market
Number of patients served
Product criticality ( Life saving product)
Product shortages
Regulatory authority
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37. The plan should include
◦ Prioritization of products based on
Process Quality history
( % batches rejected, total complaints,)
Total GMP deviations ( Critical , major , minor)
Planned process changes
Total change controls opened since last PV
Manual / High risk control strategies
Status of exiting PV documentation package
Amount of ongoing monitoring data collected for a given product
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38. The plan should include
◦ Procedure for updating plan based on new
knowledge or events
◦ Handling of products to different standards
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39. The next steps in the process are
◦ Gap & risk assessment for individual process
validation packages
◦ Alignment with revised Quality System Expectations
◦ Identification of Appropriate Remediation
The steps are summarized in the next slide
Figure 2
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41. The remediation plans can be divided into two broad categories
◦ Plans that may require actual process change including risk control
strategy improvements
◦ Plans that do not require actual process change
Changes should be implemented thorough change management
system and associated risk management activity.
Critical impact changes should be identified and controlled
See Table 1 earlier for PV program requirements
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42. Table No.2 given in next slides outlines
potential PV package Gaps for individual
processes.
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45. Poor or Missing Development Documentation
◦ Many legacy products are developed before ICH Q 8(R2)
◦ Before harmonized definition of CQA and CPP
Firm is not expected to perform missing or
missed aspect of development work
What is expected is to supplement related
documentation for established and well
controlled legacy products
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46. To manage product life cycle in the long term
it is necessary to understand the links
between the parameters and product
attributes.
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47. CQA’s and associated CPP’s can be
established based on
◦ Current and historical product and process data
◦ Characteristic attributes of the dosage form
Discovery & development based on QbD is
typically not required for legacy products
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48. However following is necessary
◦ Identification of Product Quality Attributes directly
related to Drug safety and efficacy
◦ Process parameters that need to be controlled to
assure that those attributes meet specifications
◦ Demonstration of the adequacy of the process
control strategy
◦ Validation of the process
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49. However following is necessary
◦ Tracking and trending of release and critical in-process
testing results to demonstrate process control
◦ Well controlled legacy processes do not require
additional characterization unless OPV reveals need for
improved controls
◦ In such situations risk assessments can be useful in
determining the relative criticality of parameters,
materials, or other items being modified.
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50. However following is necessary
◦ Evaluating actual deficiencies in control strategy as
reflected in test data, complaints and process deviations
◦ Above can indicate work necessary to understand and
improve control strategy
◦ Such process improvements do not drive revalidation per
se
◦ They are triggers for process improvements and then
followed by PPQ to establish effectiveness of actions.
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51. Final category of Gaps could be
◦ When legacy packages do not conform to predicate
rules effective at the time of PV execution
◦ Other significant compliance issues
This may require repeating or supplementing
initial validation simply to improve available
GMP evidence of validation
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52. In such cases revalidation utilizing PPQ plans
and protocols meeting current expectations is
recommended.
However subsequent period of enhanced
monitoring may not be required since the
process itself has not been changed
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53. Important
To understand how critical is a given parameter
or attribute to patient safety and product efficacy
To document the rationale for above
In absence of this Release specification can
considered to be critical as a conservative
method of attribute selection
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54. Important
Process parameters that must be controlled
to assure that these release specifications ar
met can be considered to be CPP”s
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55. With capable process performance & in
absence of compliance gaps
◦ Trending of critical manufacturing batch data on
ongoing basis can be a routine OPV program
◦ OPV continues till product is modified, improved or
discontinued.
◦ Level of sampling , testing and other monitoring
activities should be adjusted based on quality data.
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56. Common question
What is the relationship between OPV and
Annual Product Review ( PQR in EU)
Is there redundancy between these two
related activities
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57. 21CFR Part 211.180(e)
◦ Requires firms to maintain written records of data for
evaluating at least annually the need for changes or
improvements to specifications, manufacturing or
control procedures.
◦ “Included in the quality standard for each drug product
and drug product specifications or manufacturing or
control procedures” is the results of statistical analysis
of process capability supporting a statistical significant
confidence statement.
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58. FDA has on several occasions said that complying
with CFR 211.180 (e) does not necessarily satisfy
expectation of ongoing monitoring.
Modern Quality Science does not advocate once a
year review of process
Life cycle concept simply provides statistical
tools for process evaluation
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59. Revalidation of Legacy Products
◦ Due to process change
◦ Compliance/Documentation improvement
◦ Number of issues beyond process change
◦ See Table 3 in next slides
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62. Applies to legacy products
Assess products & processes and determine gaps
Apply Life cycle approach
Goal is same as new products
Understand impact of various sources of variability on product
quality
Implement control strategy to manage variation
Generate documented evidence verifying applicable control
strategy
Ensure robust process control
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63. Products need not be revalidated for the sake of
complying with the life cycle approach in the
absence of missing data or control issues
Remediation is related to deficiencies
Evaluate the level of routine sampling and testing
Identified gaps may lead to additional PV activity
There is no need that a firm reverse engineer well
controlled legacy processes
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64. This presentation is compiled from freely
available resources like the websites of FDA,
EMA, WHO and ISPE.
This presentation is based on a discussion paper
published by ISPE titled “ Process validation Life
cycle implication for legacy products”
“Drug Regulations” is a non profit organization
which provides free online resource to the
Pharmaceutical Professional.
Visit http://www.drugregulations.org for latest
information from the world of Pharmaceuticals.
3/31/2016 64
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Resource for Latest Information