The Biosimilar debate touches upon several important reasons for innovation failure in a regulated environment – successful, scientific, resolution will be important for the entire sector.
FDA Design Controls: What Medical Device Makers Need to KnowGreenlight Guru
FDA Design Control regulations defined in 21 CFR 820.30 have been in place for 20 years now, yet year after year they continue to be one of the top issues cited during inspections.
This does not, and should not, be the case for your medical device company.
Join us for this free, two-part webinar series presented by two of the world's leading experts on the topic to learn how to implement a design control process that will not only ensure compliance but will actually benefit your product development efforts.
(You can view both webinars here: http://www.greenlight.guru/webinar/medical-device-design-controls)
In Part 1, you'll learn about Intended Use, User Needs, Design Inputs, Design Reviews, Design History File (DHF) and Risk Management.
Specifically:
-The importance of getting your intended use right up front
-The difference between a user need and a design input that's verifiable
-What stakeholders need to be involved in the process and why
-When and how many design reviews you should hold
-Why FMEA alone is NOT risk management and how to integrate risk into the design and development process
In Part 2, you'll learn about Design Outputs, Device Master Record (DMR), Design Verification and Validation (V&V), Design Transfer and Regulatory Submissions.
Specifically:
-Why your design outputs need to be more than a drawing and their relationship to your DMR
-How usability and human factors fits into the overall product development
-Making sure you build the correct device and build it correctly with design V&V
-Common mistakes people make during design transfer to production and how to avoid them
-When you can and should make your regulatory submission
FDA Design Controls: What Medical Device Makers Need to KnowGreenlight Guru
FDA Design Control regulations defined in 21 CFR 820.30 have been in place for 20 years now, yet year after year they continue to be one of the top issues cited during inspections.
This does not, and should not, be the case for your medical device company.
Join us for this free, two-part webinar series presented by two of the world's leading experts on the topic to learn how to implement a design control process that will not only ensure compliance but will actually benefit your product development efforts.
(You can view both webinars here: http://www.greenlight.guru/webinar/medical-device-design-controls)
In Part 1, you'll learn about Intended Use, User Needs, Design Inputs, Design Reviews, Design History File (DHF) and Risk Management.
Specifically:
-The importance of getting your intended use right up front
-The difference between a user need and a design input that's verifiable
-What stakeholders need to be involved in the process and why
-When and how many design reviews you should hold
-Why FMEA alone is NOT risk management and how to integrate risk into the design and development process
In Part 2, you'll learn about Design Outputs, Device Master Record (DMR), Design Verification and Validation (V&V), Design Transfer and Regulatory Submissions.
Specifically:
-Why your design outputs need to be more than a drawing and their relationship to your DMR
-How usability and human factors fits into the overall product development
-Making sure you build the correct device and build it correctly with design V&V
-Common mistakes people make during design transfer to production and how to avoid them
-When you can and should make your regulatory submission
This paper explores biopharma industry challenges in product development and innovation, defines PLM for the industry and provides guidance on how to get started on the PLM journey.
Key to Successful Design to Manufacturing - Siddharth Desai, I-Flow Corporationmarcus evans Network
Siddharth Desai, I-Flow Corporation - Speaker at the marcus evans Medical Device Manufacturing Summit Spring 2012, held in Las Vegas, NV, delivered his presentation on Key to Successful Design to Manufacturing
Ws from innovation to commercialisation marcel van der sluisIventus
Presentation of dr. Marcel van der Sluis, Manager BD Drug Development Cluster at the Workshop 'From Innovation to Commercialisation' during the Dutch Life Sciences & Health Conference 2010
Pinch-Hitting in Heidelberg 16 October 2013Ajaz Hussain
Last minute request to fill gaps in the program due to US Gov shutdown. Key topics: Process Validation, Continuous Manufacturing, Statistical Confidence, Quality by Design.
Development of Biosimilar Products: Determinants of SuccessAjaz Hussain
After leaving FDA my focus has been on practicing QbD to deliver, in highly uncertain business environments, complex products and the necessary scientific evidence. This presentation comments on firm's ability to successfully develop and introduce into markets.
Regulatory Challenges: Lecture @ University of Michigan 21 Feb 2013Ajaz Hussain
To frame the current challenges in (the implementation of) Pharmaceutical QbD in a manner that will provide you an opportunity to:
(1) Leverage prior learning about medical device QSR to inform and understand key issues in regulation of pharmaceutical QbD
(2) Provide an example of a ‘real world’ uncertainty that you should not hesitate to take-on based on the fundamentals of engineering science and practices you have learned
This paper explores biopharma industry challenges in product development and innovation, defines PLM for the industry and provides guidance on how to get started on the PLM journey.
Key to Successful Design to Manufacturing - Siddharth Desai, I-Flow Corporationmarcus evans Network
Siddharth Desai, I-Flow Corporation - Speaker at the marcus evans Medical Device Manufacturing Summit Spring 2012, held in Las Vegas, NV, delivered his presentation on Key to Successful Design to Manufacturing
Ws from innovation to commercialisation marcel van der sluisIventus
Presentation of dr. Marcel van der Sluis, Manager BD Drug Development Cluster at the Workshop 'From Innovation to Commercialisation' during the Dutch Life Sciences & Health Conference 2010
Pinch-Hitting in Heidelberg 16 October 2013Ajaz Hussain
Last minute request to fill gaps in the program due to US Gov shutdown. Key topics: Process Validation, Continuous Manufacturing, Statistical Confidence, Quality by Design.
Development of Biosimilar Products: Determinants of SuccessAjaz Hussain
After leaving FDA my focus has been on practicing QbD to deliver, in highly uncertain business environments, complex products and the necessary scientific evidence. This presentation comments on firm's ability to successfully develop and introduce into markets.
Regulatory Challenges: Lecture @ University of Michigan 21 Feb 2013Ajaz Hussain
To frame the current challenges in (the implementation of) Pharmaceutical QbD in a manner that will provide you an opportunity to:
(1) Leverage prior learning about medical device QSR to inform and understand key issues in regulation of pharmaceutical QbD
(2) Provide an example of a ‘real world’ uncertainty that you should not hesitate to take-on based on the fundamentals of engineering science and practices you have learned
Process Analytical Technology, Quality by Design & PharmacogenomicsAjaz Hussain
Keynote address at the 2013 Scientific Conference of the Nigerian Association of Pharmacists and Pharmaceutical Scientists in the Americas (NAPPSA). The lecture attempts to 'connect the dots' between PAT and QbD to Pharmacogenomics in the context of the authors experience at the US FDA and in industry.
Technology commercialization strategy for a multidisciplinary R&D institutions such as GRO and CRO under new research and business development (R&BD) paradigm
In the current phase (controversy-free period) traditional risk-aversion to new technology is muted. The ‘pendulum shifted’ towards commercialization about a decade ago
The need for, and adequacy of, risk-assessment and risk-management in commercial setting is highly variable.
Nanoscience and nanotechnology publications often tout ‘transdisciplinary’; evidence from social science perspective suggests much of the research is ‘uni-disciplinary’.
Tactic knowledge plays a significant role in science to technology transfer; ability to do both within a group or organization is advantageous. A transdisciplinary approach to regulatory policy development would be important for efficient standardization of frameworks, concepts, tools and vocabulary.
IGPA Building a Culture of Quality Ajaz Hussain_5 Sept 2015_Rferences minAjaz Hussain
Improving Confidence in Quality of Medicines . We make two products – medicine and evidence (documents) but many forget this and do not pay attention to documentation.
Level of attention to documentation is a “canary in a coal mine”
Breaches are irrational –”System 1 thinking” and cognitive biases.
Culture of Quality is familiar to all of us – a framework proposed
Quality Metrics – great idea – very much needed; but we are not yet ready for an FDA Guidance.
We must first address our collective blind spots; be confident that process validation truly ensures complexity is sufficiently reduced and that outcomes are predictable.
Social Media Megaphone, the new Voice of the Patients. An evolving case example to observe and learn how the pharmaceutical community addresses the needs of ADHD patients and parents.
An opportunity to observe and learn (real time) from this evolving case example. I am eager to to see the reaction (hoping it is that of satisfaction) on social media when FDA reports its findings.
If there are no issues found by FDA; what will be the reaction?
If FDA changes the AB -rating (i.e., interchangeability) - what will be the reaction?
Dr Venkateswarlu Memorial Lecture 2015Ajaz Hussain
Purpose of this talk is to request you to consider the following 4 Steps
1. Strengthening the ‘Culture of Quality’ – the focus of this talk
2. Improve efficiency with confidence in controls by integrating India’s engineering and statistical know-how and technologies
3. Working together – ‘One Quality for All’ to say proudly – Made in India: Pharmaceutical Factory to the World
4. Leverage India’s Wisdom Traditions to provide leadership in setting the standards for Integrative Medicine so as to deliver a model of ‘Health Care for All’: Pharmacy to the World.
Totality of Evidence & Theraputic Equivalence 15 October 2016Ajaz Hussain
Put R back in R&D & recognize It is a “complex” product and process!
Invest smartly in analytics, mathematics & statistics, and large sample sizes; and in systems/integrative thinking and data integration
Get to know the RLD – multiple lots; open the door with large sample size
Build capability to justify measured RLD variability is relevant to development of the proposed generic/biosimilar
Exquisite regulatory communication strategy
This is not a ‘complicated process’ for which typical “good practices” will work seamlessly (e.g., typical project management approach); this is a complex process – with multiple interactions and “emergent properties”
Treat it as it is - a complex process and plan; anticipate and address “emergent issues” - in technical, regulatory and legal dimensions; at a certain point be prepared for stakeholder (payers, patient groups,..) communications
Sense of urgency, lessons learned, organizational alignment, team approach, training and an increasing engineering and statistical capability at CDER FDA can be expected to facilitate a move by industry towards continues manufacturing, FDA’s current emphasis on ‘statistical confidence’, Process Validation Guidance 2011, is likely to highlight certain issues (e.g., special causes) within current batch processing; these observation will need to be addressed in an appropriate risk-based manner
Ensuring that pragmatic consideration for specifications & control (intended use) is essential and importance of pragmatic decisions should not be forgotten (e.g., as in case of Design Space Vs. SUPAC), Effective regulatory communication (considering the engineering and statistical emphasis) will be crucial for ensuring regulatory uncertainty is managed in a timely manner,
Explaining the behavioral economics context of culture of qualityAjaz Hussain
Thank you for the many comments on Pharmaceutical Culture of Quality presentation. Some of you asked for more information to understand why I based the discussion in the context of behavioral economics (as opposed to, for example, ethics). This slide-deck provides an explanation for my decision to link culture of quality to the dimension of econometric and behavioral economics.
These slides were used for a invited presentation @ Patheon Seminar – Bridgewater, NJ, 31 July 2014.
Some modification have been made to connect the dots for the audience who will review this slide-deck on the internet.
This presentation provides a very brief snap-shot of a day long training program conducted recently at a company in India. In preparing the day long training session I had asked the following questions; (1) How to effectively communicate to an audience of a group of young and bright Indian professionals in any company in India and their supervisors/management about the importance of cGMPs and QbD? (2) How do I understand their challenges, perspectives and biases? (3) How do I connect with them to share the joy of Quality by Design?
The response received has been overwhelming from the audiences in India and yesterday at the Patheon Seminar in Bridgewater, NJ. I hope you will also the see some of the important dots and the connections. How this content connects to regulatory requirements is not covered in this slide deck – it connects via ‘A, B, C, D’ to 21 CFR, Quality Systems Approach to cGMP, ICH 7, 8, 9, 10, and 11.
Need for an Integrated approach to Formulation Research and Knowledge ManagementAjaz Hussain
1. Confidence in Generics: Need for an Integrated
approach to Formulation Research and Knowledge
Management (Ajaz Hussain)
2. Mechanism for an integrated approach to Formulation
Research, Knowledge Management, & Knowledge
sharing with FDA & Industry (Steve Byrn)
3. Integrated approach for evolving standards for
formulation design - case example NTI's (Ken Morris)
4. Integrated approach for evolving standard for analytical
characterization - case example excipient variability
(Eric Munson)
Visioning the Next Decade: NIPTE-FDA CollaborationAjaz Hussain
NIPTE Seminar at US FDA, 16 March 2016.
QBR as an Organizing Principle for the Proposed NIPTE Center of Excellence for Pharmaceutical Formulations (CEPF)
Next Generation Bioprocessing adoption for mAbs – BioContinuum™ Platform Info...Merck Life Sciences
Learn more on the opportunities and hurdles of intensified, connected or continuous processing. 30 US and European biomanufacturers were interviewed to understand the likely future adoption of ‘Next Generation Bioprocessing’.
Discover the animated version! http://www.merckmillipore.com/INTL/en/20180329_155610?bd=1&tab=2
Visit the BioContinuum™ Platform webpage now! http://www.merckmillipore.com/biocontinuum
Quality by Design Principles Applied to Sterilizing Filtration by Michael PayneMilliporeSigma
Key regulatory documents and regulatory thinking now includes quality by design (QbD). This webinar focuses on how to integrate practical QbD activities into the process and analytical aspects of sterile medicinal product sterilizing filtration and qualification.
In this webinar, you will learn to:
• Focus on practical QbD terms and approaches
• Highlight critical product quality aspects of sterile medicinal products
• Develop design and control spaces for sterilizing filtration
• Easily integrate QbD into the process and analytical operations in early phase development and into manufacturing phase production
Abstract:
Final sterilizing filtration is the last operation in downstream processing to assure the sterility of medicinal products. Poorly defined product attributes process parameters may attract regulatory scrutiny, affect final product sterility and patient safety. A better understanding of QbD concepts and principles allows for better process and analytical monitoring and control at both early and final phase production. The webinar will show how currently available process cGMP information can be practically incorporated into QbD product quality attributes and process parameters. This is especially vital for the third party conducted laboratory work such as bacterial retention and leachable studies.
Quality by Design Principles Applied to Sterilizing Filtration by Michael PayneMerck Life Sciences
Key regulatory documents and regulatory thinking now includes quality by design (QbD). This webinar focuses on how to integrate practical QbD activities into the process and analytical aspects of sterile medicinal product sterilizing filtration and qualification.
In this webinar, you will learn to:
• Focus on practical QbD terms and approaches
• Highlight critical product quality aspects of sterile medicinal products
• Develop design and control spaces for sterilizing filtration
• Easily integrate QbD into the process and analytical operations in early phase development and into manufacturing phase production
Abstract:
Final sterilizing filtration is the last operation in downstream processing to assure the sterility of medicinal products. Poorly defined product attributes process parameters may attract regulatory scrutiny, affect final product sterility and patient safety. A better understanding of QbD concepts and principles allows for better process and analytical monitoring and control at both early and final phase production. The webinar will show how currently available process cGMP information can be practically incorporated into QbD product quality attributes and process parameters. This is especially vital for the third party conducted laboratory work such as bacterial retention and leachable studies.
The students will get a glimpse of industrial bioprocess from this presentation. Additionally, it will help students make the transition from academia to industry.
Design Controls: Building Objective Evidence and Process Architecture to Mee...April Bright
This session provides detailed examples to demonstrate what objective evidence is important to generate and use during design control compliance but, more importantly, to develop and issue a beneficial design history file meeting the requirements in 21 CFR, Part 820.30 and ISO 13485:2016. Aside from the importance of design controls for compliance, Mr. Gagliardi demonstrates how this section of the QS regulation and the ISO standard can be facilitated as a leading edge business tool.
A Leapfrog Need and Opportunity for mAbsAjaz Hussain
Leapfrogging on reforming mAbs policies makes sense, and doing so can be a principled duty of care.
SMART Technology, SMART Professionals, SMART Services, SMART Organization.
SMART Quality by Design Applications Not Submissions in 2024Ajaz Hussain
Many generic pharma companies seeking regulatory approval uncritically follow “past” practices and prior knowledge. Few, if any, correct errors and innovate to improve past expertise and techniques. The idea of SMART "QbD in ANDApplications" (not “submission”) builds on this observation.
Intuitively Moving Institutions Towards Global Regulatory Resilience Ajaz Hussain
From my experience, how can I describe an intuitive and self-organizing social force around "attractors" patients' value to be assured of therapeutic equivalence?
Critical Importance of Pharmaceutical Traceability in the Experience.pdfAjaz Hussain
From a narrow viewpoint, serialization is just a process of printing an identifying number on products and shipping cases.
From a long-term view, the integration of serialization numbering systems with the production line as well as the quality control procedures required to maintain the integrity of the numbers.
Validation 4 for Credible Pharma 4 a Keynote for Valconnect 2023.pdfAjaz Hussain
The notion of Validation 4.0 in the title of this keynote relates to the development and maturity of people and professionals, which I will elaborate on in the context of the ValGenesis experiences [of its users and service providers].
Validation 4.0 in this talk is about internal assurance, self-assurance, and self-authoring policies, plans, and procedures, ideally without the need [to wait] for FDA guidance.
SMART Triaxial Compaction, Social Form 483 and VAI or OAI to an Avenger.pdfAjaz Hussain
Why did the company not design and formulate a tablet that did not “cap”? Why wouldn’t NIH fund my proposal for CAFD? Why did the FDA [discount] Pharmaceutical Development Reports, while in the EU and Japan, is it an essential part of the regulatory review?
Under a hypothetical social inspection scheme, a report submitted in 2010 is imagined as PM 483 in the spirit of FDA Form 483 of “Inspectional Observations.”
What do the noted observations suggest about my professional maturity or state of mind at that event in 2010? What would be an appropriate “feedback” response?
Statistical Thinking and Pharmaceutical Professional Development, a keynote b...Ajaz Hussain
In adulthood, to keep maturing, one must acknowledge the elephant in the room – the emotions we feel. To feel is to experience. Experience complements our scientific training. But do we pay attention to the Integrity of our experience? A tonic for wiser statistical thinking to inform the development of pharmaceuticals and professionals.
An Updating Perspective on BAD I in March Madness 2023.pdfAjaz Hussain
Why does it take decades to acknowledge the obvious? Something to ponder and write about. How do you suggest we keep moving closer to the truth? Can we simultaneously personalize our minds, machines, and medicines to develop continuously? How? I am sharing a slide deck of thoughts to discuss meaning-making and the Federal Food, Drug, and Cosmetic Act (FD&C Act) in the context of the post-truth world, which I collected to populate two invited lectures at the University of Minnesota, College of Pharmacy. The slides I am uploading here are in reverse order, 2nd lecture followed by the first. It is, to begin with, a journey to 2020+ to note that the root cause of BAD-I is I and to pose a challenging premise that beyond the age of majority, few adults continue to develop and mature. What evidence warrants this premise, and why? Then how to develop and mature continuously as an adult and a professional.
Mature Managers and Management of Pharmaceutical Quality and QuantitiesAjaz Hussain
We live in a post-truth world, and we like to think we are good. Are we? Do we not need ALCOA for the integrity of our experience?
Remember: Experience means to feel; how you feel determines what you learn! Honoring my grandmother’s advice, keeping intentions clean, इरादों को साफ रखें to begin to recognize a pattern of interactions between how I feel, what I think to explain why I behaved in a certain way.
Some of my thoughts on SMART Objective negotiations and to be better at SMART Experiencing than SMART Machines. The content describes insights from observing the immaturity of political, regulating, and management systems. Why does “immature” claim “I am mature” when it shouldn't?
I-SMART Internal Validation for Continuous Professional Development.pdfAjaz Hussain
i-SMART: Internal validation [is] continuous [professional development]. It is a journey within and without. In the growing chaos, it is urgent and essential that we must be the change we seek in the world. Be I-SMART! #Validaiton #good
S.M.A.R.T Pharmaceuticals 2021 -2030: AI or Human?Ajaz Hussain
Take a smart “development stance” to prepare for 2022 and beyond, envision your journey to 2030. Spiral high and wide like a migratory bird. Recall, Reflect, Research, Remember, Reset and Rebuild: Recycling necessary but not sufficient.
https://www.linkedin.com/pulse/recall-reflect-research-remember-reset-rebuild-ajaz-hussain-ph-d-/?trackingId=aF5BbJF0T5%2B036rQ7Zw3gA%3D%3D
Sustain and Build a Quality Culture in Today's RealitiesAjaz Hussain
What is quality, what is culture? Culture, quality, and assurance are just a few of the many abstract words in our lexicon. The meaning we make evolves with our development and maturity. Our education and training are necessary but insufficient for our development and maturity. Learning from experience is essential, and experiential learning is highly variable. Some continue to develop, but at different rates; others do not. In this presentation, I share why and how a connect-the-dots framework was developed and what it offers to individuals and organizations. Building refers to a process by which a source code guides software coding programs for a stand-alone computer or an enterprise-wide system. The context of this presentation is experiential. The content is derived from experiencing the real world via an intentional journey beginning in 2015 across the globe; since 2020, this journey has been searching for the source code to what is good. In my imagination and thought experiments, the building is a process, as in the context of software development. Coding for a stand-alone computer is similar but not interchangeable or automatically substitutable for writing and executing a personal or individualized continuous professional development plan. I speak about quality culture to ease the process of continuous learning, development, and maturity in professionals and management systems. To improve feedback and encourage backpropagation of errors of omission and commission to learn how to prevent mistakes and improve continually, I remind that it is increasingly relevant today to begin asking - how might we assess suitability, capability, and comparability of humans and AI in the context of CGMP compliance and maturity of a pQMS. I implicitly use the lexicon of biosimilars, interchangeable biosimilar products, and automatic generic substitution for brand products to help us make sense of our suitability and capability to know the difference in the maturity stages we call professional and good practitioners to appreciate the differences in the regulatory and social expectation of validation and assurance broadly and specifically as in the validation of computer and pharmaceutical systems.
Managing Pharmaceutical Quality in Traditional Paradigm and in the Emerging “...Ajaz Hussain
The epistemic crisis has deepened; multiple systems are now chaotic, fear and anxiety unabated and as expected the dominant response to the crisis is procrustean. Scenarios to consider managing pharmaceutical quality design space in traditional paradigm and in the emerging “SMARTness”?
Design is to do good not just be and look good: Bad Design is Smoke, Good Des...Ajaz Hussain
Design is to do good not just be and look good. "Design means being good, not just looking good." ~ Clement Mok. "A small change at the beginning of the design process defines an entirely different product at the end." ~ Jonathan Ive. "User-centered design means understanding what your users need, how they think, and how they behave - and incorporating that understanding into every aspect of your process." ~ Jesse James Garrett.
Compared to “one factor at a time” experiments, increased experimental efficiency, accounting interactions, multivariate predictive capability, minimization, maximization, optimization, graphical illustration for enhanced communication of complex topics.
"Design is intelligence made visible." -- Alina Wheeler
Pharmaceutical Quality in the 21st Century, Current Status of PAT & QbDAjaz Hussain
What we know is not what we implement in practice is the shadow in our development—walking a tight rope across the precipice with an elephant on my back. Is an Elephant on My Back the apt metaphor to replace the Six Blind Men and an Elephant and an Elephant in the Dark?
Meaning making measurement maturity and management mokshaAjaz Hussain
Power without wisdom is a recipe for disaster. “Your problem is not technology. The problem is you. You lack the will to change” (The Day the Earth Stood Still (2008). “I think we need to do some very serious soul searching,” Woodcock (2020). Adequate, well-controlled, qualified by training and experience, fairly, responsibly (FD&C Act). “Only at the precipice do we evolve.” Is this our moment? Profiteers learn to be patient. Exploitation & Exploration: Bottom and Toplines, the ambidextrous. Quality is integral; warrant connects quantitative evidence with claims. Cease dependence on inspection via maturity of self, systems, & societies. You can find the way forward [to maturity] in the heart. Sense within to awaken. Dil Se! By heart.
Equivalence Assessment and Maturity of Quality Management SystemsAjaz Hussain
Challenge: As a system or cohort, we can do more to adequately appreciate that “systems” proficiency is a stage in adult development that most struggle to achieve.
Professionals and human experience: Ex[CI]perience Lessons in Excipients Ajaz Hussain
Alone together, civil war, same difference, unbiased opinion, and the "hindsight is always 20/20" feels oxymoronic. What space will excipients occupy in our consciousness in the next decade?
Compliance in the Age of Lockdowns & Disruptions: Reconciling Different Persp...
Will Biosimilars Be A Driver For Innovation
1. Will Biosimilars be an Important Driver
for Innovation and Continual
Improvement in Biopharmaceutical
Manufacturing?
Ajaz S. Hussain, Ph.D.
A Keynote Address: Business of Biosimilars
September 20‐22, 2010, Hyatt Regency,
Boston, MA
www.biosimilarsevent.com
3. Innovation
• “The act of introducing something new” (the
American Heritage Dictionary)
• “A new idea, method or device” (Webster
online)
• “Change that creates a new dimension of
performance” (Peter Drucker)
• “The ability to deliver new value to a customer”
(Jose Campos)
4. Product & Process Innovation*
(outside the pharmaceutical sector)
Rate of Innovation
Rate of Product Innovation
Rate of Process Innovation #1
Dominant Design
Rate of Process Innovation #2
performance maximization sales maximization cost minimization
uncoordinated segmental systemic Time
*A modified representation of the Utterback‐Abernathy´s model of industrial
product and process innovation. The Int. J. Mgmt Sci., Vol. 3, No. 6, 639–656 (1975)
5. Innovation Modes, Innovation Failure, Typical
Sectors, and Policy Response
Mode of Innovation Typical Policy
Innovation Failure Sector Instruments
• Application •Knowledge •Biotech., • High‐tech
of high‐ originates material bridging
science outside science,… institutions
technology commercial to facilitate
sector – this diffusion of
is not well advances
communi‐
cated to
Regulatory potential Competing Regulatory
Acceptance Interests Guidelines
users
Research Policy. 29: 437 (2000)
7. Process Design Through Analytical &
Process Integration: ‘Biosimilar Delta’
Driver for process innovation
If timely acceptance by regulators
Product Innovation
Innovation
2nd Generation ry
Product o ve
sc
Launch Di
Process Innovation
Development (industry wide or Biosim)
1st Generation
Product Biosimilar Product
Launch
Biosim Delta 1st Generation Product
Regulatory Process
‘Originator Delta’
sales maximization cost minimization
segmental systemic Time
8. My Point of View
• Will Biosimilars be an Important Driver for Innovation and
Continual Improvement in Biopharmaceutical Manufacturing?
• No
– Competition, by shifting demand, can be a driver for product
innovation. However, competition can not be expected to be an
important driver for process innovation
– High, non‐scientific, barriers to entry (product approval & designation)
will ensure that process innovation remains only an option that some in
industry will exercise
– Recent financial crisis may have reemphasized the need for process
innovation and/or may altered the course of process innovation
but…….our society is not yet prepared to address important reasons for
innovation failure in a regulated environment
• But, the Biosimilar debate touches upon several important reasons
for innovation failure in a regulated environment
12. Types of Improvement
CAPA Continual Improvement Innovation
Product is out of Product is within Revolutionary, to be a
“specification” (OOS) “specifications” leader
or there are Acceptance criteria ‐ ROI, Top‐down
procedural deviations variable/continuous Project based
ʺCrisisʺ ‐ immediate data Specialist/Technical
action needed Evolutionary, experts involved
Required by incremental, daily Superior ability to
regulators activity justify specifications
Carried out by plant and convince
and quality staff regulators
ʺDrive out fearʺ that inhibits continuous learning and improvement ‐“Specifications”
www.fda.gov/ohrms/dockets/ac/04/.../2004‐4080b1_01_manufSciWP.pdf
13. Specification ‐ Uncertainty
Quality –to-
Clinical gap is
a significant
challenge!
Regulatory
specifications
established
after “clinical
trials”
CMC Review –
CGMP Inspection
Disconnect
Specification –
Capability:
Disconnect
http://www.fda.gov/OHRMS/DOCKETS/AC/05/slides/2005‐4137S1_06_Hussain.ppt#371,11,Quality – Clinical Gap: Uncertainty
23. My Point of View
• Will Biosimilars be an Important Driver for Innovation and Continual
Improvement in Biopharmaceutical Manufacturing?
• No
– Competition, by shifting demand, can be a driver for product innovation.
However, competition can not be expected to be an important driver for process
innovation
– High, non‐scientific, barriers to entry (product approval & designation) will
ensure that process innovation remains only an option that some in industry will
exercise
– Recent financial crisis may have reemphasized the need for process innovation
and/or may altered the course of process innovation but…….our society is not
yet prepared to address important reasons for innovation failure in a regulated
environment
• The Biosimilar debate touches upon several important reasons for
innovation failure in a regulated environment – successful,
scientific, resolution will be important for the entire
sector