Tuesday, December 1, 2009

Tech Transfer

Technology transfer is not always as simple as it might seem. Contract manufacturers produce a wide variety of biopharmaceutical products for their pharmaceutical and biotechnology clients, and no two projects are the same. Therefore, no two technology transfers are the same. In addition, the technology involved in scale-up manufacturing of biopharmaceuticals is complex, often requiring a substantial amount of process development before production goals can be achieved.

Although most companies refer to “technology transfer” as if it were a standard process, there are several forms of this transfer, each requiring different degrees of process development. For a large pharmaceutical company that already produces a particular drug on a commercial scale and wants to hand off the production to a contractor, the transfer process can be fairly straightforward. In this instance, detailed documentation and an analysis of equipment and process compatibility may ensure a smooth transition.

When large-scale production has not been achieved by the client on a consistent basis, however, the client and contractor must see to it that every step of the process in scale up will meet regulatory requirements as well as quality, cost and time targets. For a client that has lab-scale technology and wants large-scale production from the contractor, extensive process development may be required.

Having dealt with scale-up and regulatory issues for many clients, the major biopharmaceutical contractors are in a position to provide a global perspective on the entire process, often (1) saving their clients time in moving to scale up, (2) heading off regulatory problems, (3) increasing quality and yields and (4) providing the client with economical yet high-quality production.

Challenges
The 10 biopharmaceutical contract manufacturers interviewed for this article cite numerous challenges involved in transferring technologies from their clients’ sites, challenges they attempt to mitigate by establishing technology transfer teams, technology transfer plans and standard contracts.

Because of the time-to-market pressures in the pharmaceutical industry, clients often urge contractors to get a product into large-scale production quickly; speed is of the essence. This urgency, however, should not provoke the client or the contractor into moving too quickly without an understanding of the full project and operational logistics. A test of all processes at scale-up level—such as analytical methods, cell lines and recovery and purification—as well as a thorough review of regulatory compliance issues, should be completed first.

The scale-up production phase will be reached more quickly if problem areas are identified and solved early on. Experienced contractors may be able to speed the technology transfer and process development phases of the project based on the exper-tise they have developed over time. In addition, contractors with a strong service orientation will be able to react quickly to any changes that may be required.

The move to large-scale production can be a challenge if the client has not consistently run the process at full scale already. In some cases, it is also a challenge for the contractor and client to agree on what is needed to proceed to commercial production.

Strong communication between client and contractor is essential, as is a process for developing agreements. Contractors say that communication skills are the keys to a successful outsourcing partnership and that flexibility is important on both sides when adjustments need to be made. Critical process information from the client site—such as hold times between steps, purification data, cell line stability and complete batch records—must be communicated. A complete process history should be transferred so the contractor knows as much as about the process as the client does, once the project begins.

Not all clients want to communicate in the same manner. Contractors must accommodate a broad spectrum of communication styles, from clients who only want to receive weekly updates on the progress of their process development and scale-up production to those who want to have a “man-in-the-plant” so that joint decisions can be made daily.

Key Elements
Contractors, from the full service providers to the smaller niche service and materials suppliers, must deal with the unique aspects of their clients’ cell lines and processes. A summary of the key elements of successful technology transfers and process development programs for scale-up manufacturing of biopharmaceuticals, as suggested by contract manufacturers, is listed in Table 1.

The following comments from 10 contract manufacturers can help sponsors understand how contractors address technology transfer and the accompanying process development and scale-up challenges.

The Technology Transfer Team
Bio Science Contract Production has a technology transfer plan that involves an integrated team of professionals from production and quality groups as well as a liaison for internal and external communication. Dr. Don Durham, vice president of technology management and process development, said, “Forming this team is the core step in securing the success of the project. The transfer team is involved throughout the entire start-up phase until the cGMP production is running smoothly and the production record is finalized.”

After the team has been formed, it is important to ensure that all of the required information has been transferred, including information on equipment, raw materials, processes, analytical and quality requirements and assay validation. Said Dr. Durham, “It is preferable that we go to the client facility and observe their process. Then we make detailed schematics and process flow diagrams for each unit of operation and include all aspects, such as equipment, supplies, part numbers, SOPs and in-process assays, among many others.” The diagrams are used to train staff and to write production records, which the client reviews as part of an ongoing line of communication.

From this documentation a demonstration run is conducted to identify any possible problem areas. “In short,” Dr. Durham remarked, “the technology transfer team works out all of the engineering aspects, ensures all information is transferred, plans for scale up, makes the site visits, identifies the material, drafts the documentation, participates in the demonstration run, assists with finalizing the documentation and then participates in the production run.”

Louise Campbell-Blair, the company’s vice president of business development, added, “Many clients want to transfer their technology directly to us and have us start production immediately, but we find that we often need a process development step first. Clients might not think about how resins, column loading or membranes scale up, for example. It is essential that the time be spent upfront to ensure cGMP compliant production of an acceptable product and avoid costly delays that might occur later in the production run if these steps had not been taken. The advantage of our approach is that process development and technology transfer are in the same department.”

Face to Face and Team to Team
Exchanging personnel from team to team at the beginning of every project is a key for DSM Biologics North America. Dr. Peter Van Hoorn, the company’s marketing and sales director, remarked, “Learning about team chemistry is important to successful technology transfer. All members of the DSM project teams that are assembled on a contract-by-contract basis have to be aware of their roles and responsibilities: Who is our client and its representatives? Who is my individual counterpart? What are the client’s expectations? Who makes up the team from the client side? What is their mindset?”

It is important to lay the foundation for a successful project in the very early stages. Dr. Van Hoorn commented, “If you casually stroll into the process, both the client and the contractor can get hurt. Even before the contract is signed, the potential problems and pitfalls must be gauged and the deliverables from both contractor and client accurately assessed. For example, if a client tells us an assay is robust for Phase I, and we later find out that such a validated assay can be anything but robust, then we have a problem.”

Timelines are often based on early assessments, so projects that have been started superficially or under extreme time pressure tend to have ever-changing schedules. Situations need to be turned around quickly. Clients want an aggressive timeline and this can only be facilitated by laying down a strong foundation in the beginning of the project.

For DSM, if an upstream process must be developed, the process personnel from the client side will come to the DSM site to re-run what has already been performed; the DSM team will build the process up from there. Client personnel is often on-site and DSM has taken precautions to ensure that confidentiality between different projects is maintained on those occasions. “Analytics and downstream purification steps tend to transfer and scale well if the equipment is similar, scaleablity has been addressed and deliverables from the client have been verified,” Dr. Van Hoorn commented. “But upstream processes, which entail highly critical customized components in cell culture and fermentation, can cause problems. Having a ‘man-in-the-plant’ is key, especially for the upstream processes. This is also true for recovery operations in E.Coli fermentation.”

Think Through the Process
For a pharmaceutical or biotechnology company developing a drug, the most important question is whether the molecule will work or not. The contractor is often responsible for ensuring that the expression system will work, is economical and will be approved by the FDA. Dr. Claire Thuning-Roberson, executive vice president of corporate development and chief scientific officer of Goodwin Biotechnology, said, “It is crucial that the process be thought through from start to finish. Each division needs to be aware of the entire process. The movement from research to development should not be a leap of faith.”

The contractor should be an extension of the client company’s capabilities and all critical information between partners should be communicated. Dr. Thuning-Roberson added, “We look at the process, the systems and what is expected. Is it scaleable, validatable, measurable, reproducible, controllable, compliant and humanly possible? Regarding the raw materials, one problematic area, are they traceable, measurable, acceptable or removable?”

The contract manufacturer must strive to understand not only the manufacturing technology required for each product, but also the client’s strategy for product development. “By understanding this,” Dr. Thuning-Roberson continued, “the vendor can work with the client to develop a manufacturing strategy that assures objectives are met with no surprises. For example, we are often asked for regulatory advice. Selecting a host cell line that will withstand FDA scrutiny is an important consideration at the research bench. Before entering into manufacturing contracts, the host cell line and manufacturing technology must be evaluated and its compatibility with FDA regulations determined.”

Purification processes developed at the research bench often require modifications in order to be scaleable and FDA compliant. Dr. Thuning-Roberson commented, “One project involved the transfer of a five-column process without stability data on bulk intermediates. Consequently, a 24-hour processing was required to minimize holding times. In another situation, reversing the order of columns in a transferred process resulted in reducing viral and endotoxin levels that were contaminating subsequent columns and equipment.” Forward thinking is vital as products are moved through process development and production toward FDA approval. She explained, “This translates into identifying potential problems and addressing them early on during technology transfer and in development.”

The Technology Transfer Plan and Timeline
The client-contractor relationship is best established by a comprehensive technology transfer plan and a timeline showing all deliverables and expected lead times for both parties. This should be preceded by an exchange of complete and accurate documentation, a site visit and an analysis of the details that may affect the transfer such as product sensitivity to environmental conditions and toxicity. Julie Carrière, manager, PDS systems & technology transfer at Patheon, recommended that business contracts be developed and signed by both parties. “There should be one contract for the technology transfer and one for on-going commercial production at the contractor site,” she said. “Both parties can then enter the relationship with a clear understanding of expectations.”

The technology transfer plan she suggested details the steps of the transfer, including final equipment and batch sizes for commercial production. The topics cover a wide range of issues that impact the transfer strategy and timeline, including documentation of toxicity, production size requirements, processes and equipment, capital expenditures, drug substance availability, analytical methods, materials sourcing, transfer and validation strategy, regulatory filing requirements and approval dates, product launch and contacts at both client and contractor site needed for each step of the project. Ms. Carrière said, “We understand the importance of accurate plans that detail the responsibilities and expected turnaround for each deliverable. Each party agrees to this plan up-front and there are no surprises.”

A Complete Process History
Marathon Biopharmaceuticals provides process development, scale up and commercial manufacture of recombinant proteins at the 10- to 2500-L scale in its FDA-inspected cGMP facility. The company was purchased by CoPharma, Inc. in January 2000.

Dr. John T. O’Loughlin, vice president and chief technical officer at Marathon, commented that the need for a complete detailed process history during the technology transfer process cannot be overstated. “It should start with a process diagram containing stepwise recovery and mass balance calculations for the unit operations. We must know as much as we can about the host strain and any unique growth requirements,” he remarked.

A thorough description of the primary recovery and downstream purification processes should be available, he contended. The documentation should include a sampling plan, potential hold points and a complete list of raw materials and their sources.

“At bench or early pilot scale, process hold points and the stability of process intermediates are generally not issues,” he assured. “However, implementation of the process at production scale in a cGMP environment imposes a different set of logistics. The stability of process intermediates must be known so we can define the unit operations. This knowledge allows us to forward schedule equipment and personnel.”

Dr. O’Loughlin added, “A clear development history will help to identify critical steps in the process and will become invaluable during process validation.” This process history becomes an essential component of final submissions to regulatory agencies. He said, “We are one of the few independent contract manufacturers that is producing a licensed biologic. To do so, our personnel performed all of the development and CMC work on that product.” Dr. O’Loughlin added that the FDA looked closely at the company’s experience in development and processing during both the pre-approval inspection at Marathon and during a series of CMC meetings at the Agency.”



Prepare for Regulatory Requirements

To ensure regulatory approval, it is critical that time be spent upfront to ensure the production process will be cGMP compliant. Ed Branson, vice president of manufacturing at Covance Biotechnology Services, commented, “We work with our clients to ensure all our ducks are lined up for cGMP operation and validation as we make clinical materials. For clinical materials, we validate equipment, systems and utilities; process validation comes at a later time. We use extensive analytical support from the QC department to maintain the quality of the process.”

Clients sometimes expect that production is standardized and that scale-up production will be similar to lab scale. But no two cell lines are the same; large scale is sometimes vastly different from lab scale. Mr. Branson explained, “We work with a dozen new cell lines a year and some never make it to production, often for productivity, stability or biological activity reasons. We tweak the media, purification scheme and other components to make the process work, which can involve some hard choices.”

Working together toward regulatory approval of a production process requires a solid understanding of expectations and trust between client and contractor. Mr. Branson remarked, “Our clients give us their baby to bring to adulthood. They have taken it as far as they can and they must trust that we have their best interest at heart. This requires that they tell us everything they have learned about the process so far.” Covance has a process development group that typically works on stability testing and scale-up issues. Afterward, a project is turned over to the technical services group, which specializes in transferring the process into large-scale manufacturing.

If the project requires a straight transfer of the technology from the client site, the company minimizes the regulatory impact by running the process as a mirror image of the client’s process. “We come as close as we can to the original process so the FDA can see that the material made at our facility is the same as the material made at the client site,” said Mr. Branson.

Communication is Key
The underpinnings of a good technology transfer program include a clear and effective mechanism for communication between the client and the contractor. Dr. Mark Carver, head of research and development at Avecia LifeScience Mol-ecules, explained, “The first thing is to ensure that what the client wants is actually what the client needs. For example, some of the analytical methods used by clients could be suitable for current requirements but unsuitable for validation and verification down the road. These things have to be determined upfront by establishing a good mechanism of communication and a clear understanding of where we are and where we are going.”

Dr. Carver stated that the client and the contractor should agree in advance to a clear, relevant structure for the technology transfer program, defining what information and processes are required. All of the issues in the technology transfer process should be reviewed and verified. He remarked, “Our client might have a recombinant microorganism, but in scale up the recombinant could be unstable, produce an aberrant form of the protein product or not produce a high enough yield. We have to verify with the client that what the client thinks has been transferred truly has been transferred, so we have a real starting point to the project.” Without a clear starting point, he added, the endpoint will be unclear.

Dr. Carver commented, “Our philosophy is that the customer is an intrinsic and fundamental part of our team and we involve them throughout the project. For technology transfer, their involvement is essential if we are to deliver a good cost and a quality product quickly. We have experience in knowing what questions to ask and what is involved in the critical path. With good experience, discipline and communication, we can move quickly to the project’s endpoint and deliver the customers’ needs.”

Flexibility
Because customers’ projects and cell lines are so different, it is essential that a contractor design flexibility into the facilities, equipment and company mindset. Dr. Friedrich Nachtman, head of bioproducts at Biochemie, said, “It is not realistic to think that a cookbook solution will work for each of our clients. One of the benefits of our service is our flexibility in equipment and people to adapt to the needs of the client and still meet high quality standards.”

This flexibility extends to the way the company personally in-volves key people from the client company. Technical experts from Biochemie will visit customer sites to observe the process and work with the client. When the production is started at the Biochemie site, the client comes to give input and make joint decisions. Dr. Nachtman commented, “People are the important part of this process. With the right attitude on both sides, the whole project will work. In addition, it is important to set realistic expectations with the client, establish clear timelines and write up a precise agreement describing the deliverables of both parties.”

Biochemie produces recombinant products for its own use and for outside clients. Explained Dr. Nacht-man, “We treat our clients’ products as if they were our own. We treat all things in the same way to ensure the clients get what they want.”

Extensive Documentation
INTELLIgene Expressions devotes a separate ‘pilot’ facility for those technology transfer and process development needs that typically arise in advance of cGMP-level needs. For projects in the early stages of technology transfer, this work is instrumental in paving a smooth transition to cGMP-level production. Dr. Fahar Merchant, the company’s president and chief executive officer, explained, “We invite our clients’ technical scientists on site to work with us to develop their process. Through this collaboration we become familiar with their therapeutic in our process development facility before the full production run.” This tacit knowledge of the client is then made explicit through careful record-keeping. The level of documentation is extensive.

INTELLIgene’s technology transfer process begins with a 12-page questionnaire used to obtain all of the technical information about the client’s process. Next, clients are asked to provide internal SOPs and batch records so that they can be examined well in advance of beginning a run in the process development plant. This information, along with other supporting documentation, helps to identify potential problems before they happen and ensures a smooth transition, according to the company.

Clients are encouraged to take an active role in the process, but the level of involvement varies, according to Dr. Merchant. “Sometimes, client personnel will join us at all of the different stages: molecular biologists for development, process engineers for production, quality control staff for analysis and monitoring.” Once the process is successful, the company readies the developmental batch records for cGMP production, has its internal QA group review all documents and seeks client approval. This close association facilitates creative problem solving. Dr. Merchant noted, “For a recent customer, this work we performed upfront resulted in a successful tenfold scale up the first time we did the run in the cGMP production facility.”

Other clients, for geographical or other reasons, are more removed from the process. In these cases, INTELLIgene controls the trouble-shooting. One such customer requested that the company produce a clinical batch in a very short timeframe. Dr. Merchant recalled, “The project manager and process scientists could visit us only sparingly. They gave us home phone numbers so we could call them in the middle of the night if absolutely required.” To complicate matters, the client’s process was not economically viable. “They came in with a 12-step purification process: a validation nightmare,” he said. “We determined a way to decrease their purification process to two chromatography steps. As a side benefit, this also increased the yields.”

Maximum Productivity
At Lonza Biologics, clients do not typically transfer in technology. Instead, they request that Lonza develop the process technology for efficient scale-up production. The first step in the process at Lonza is an upfront, detailed discussion with clients to define the overall objectives and to understand how Lonza’s knowledge and experience will be used to fine-tune the process to meet time and price goals. Clients may choose to incorporate Lonza’s proprietary expression system into their production plan.

As Mike Chaffee, director of marketing, described it, “To produce robust, scaleable processes, we evaluate a number of critical parameters maximizing the expression levels from the cell line.” He added, “We also examine batch or fed batch production strategies utilizing airlift or stirred tank technologies. In addition, we typically examine media selection and look at the benefits of utilizing serum-free or protein-free conditions. It is amazing how minor changes in the process, such as changes in pH or media components, can have dramatic results in productivity. Downstream, for purification, we look at filters, centrifuges, chromatography and overall recovery to maximize the productivity of the process.” Each project is customized and the client has the option of transferring all or some of Lonza’s relevant intellectual property back in-house.

Ultimately, there is no single recipe for all projects. In more complex situations, working with cells can be more of an art than a science. The expertise or intellectual property that a contractor offers the client will often significantly help bring that product to the market. Mike Chaffee noted, “We have helped dozens of clients speed their product to market by utilizing our knowledge base in development, optimization and scale up of the production process.”

Outsourcing offers companies a new option in this regulatory process

By Dilip M. Parikh
Atlantic Pharmaceutical Services, Inc.

Pre-Approval Inspections (PAI) have become a prerequisite to launch an NDA or ANDA product in the U.S. The origin of this inspection can be traced back to generic drug industry scandals in the late 1980s. At that time, one could make bench scale batches of a product and submit the application for approval. It was only after approval that companies customarily started to develop the process for production. Purchasing, installing and qualifying the equipment was considered only after the approval of the product. From a business standpoint, this made perfect sense.

One of the flaws of that system was that process scale up, as well as the changes that were normally required to be made during the development and scale-up effort, did not reflect what was submitted to the FDA as the process that would be used commercially. With the implementation of PAI, some companies proceeded to set up plants to manufacture their products commercially, only to find out several years later that the drug did not get approval from the FDA. The concept of process validation, although part of regulations from the beginning, was brought to the forefront. When one examines the statistics of recalls, lack of validation is one of the main reasons why products do not conform from batch to batch. Usually, the robustness of the process was not investigated before the marketing of the product.

The initial impact of the PAI requirement from FDA was confusion. Several companies failed to pass this new requirement from the agency. Table 1 (p. 48 of the magazine) illustrates the recent enforcement trends. In 1997, the FDA issued 1,140 warning letters, the majority for medical devices (369), drug violations (266), food and cosmetics (220), animal drugs and feeds (148) and biologicals (68). The FDA’s volume of enforcement actions decreased in the mid-1990s; however, these changes likely do not reflect any shift in the FDA’s emphasis on rigorous enforcement. Rather, the declines may be due to several independent factors, including: “leveling off” from record levels of court actions in 1992; a concentration on larger, landmark cases; and, in some areas, the effects of new organizational structures and reduced resources within the agency. The implementation of PAIs for new drugs may also be one of the contributing factors in the reduction of prosecutions over the years.

The 1998 PAI data shows facilities abroad outperforming U.S. plants. These favorable foreign PAI results parallel FDA’s enforcement data for fiscal year 1998, which shows a significant reduction in the number of warning letters issued to overseas plants. This improved compliance record reflects a concerted effort by the agency over the past few years to bring foreign Active Pharmaceutical Ingredient (API) manufacturers into compliance through increased enforcement oversight and better GMP guidance. During 1998, FDA’s field organization conducted 1,016 inspections. The types of plants covered included contract laboratories, packagers and manufacturers as well as bulk and finished dosage manufacturers.

Table 2 (see p. 50 in magazine) provides a summary of the field pre-approval recommendations with or without inspections and Table 3 (see p. 52 in magazine) shows the issues implicated in “withhold” recommendations for both NDAs and ANDAs.

There is a move within FDA and in industry to form GMP compliance partnerships. FDA has already opted to perform fewer pre-approval inspections in light of the industry’s im-proving compliance track record. The First-Party Audit program provides for drug firms with solid track records of GMP compliance to submit internal audit findings to the FDA in lieu of routine agency on-site inspections. FDA’s district offices are encouraging firms to initiate a dialogue about the production of new chemical entities, manufacturing changes and construction of new facilities before application and supplements are filed with the center, in order to avoid major GMP problems later on.

“Plant-not-ready” has been the primary reason for withholding recommendations during the past several years despite FDA’s efforts to warn firms that the time between the actual filing of an application or supplement and the scheduling of the PAI has been reduced.

The general assumption one should go with is, “Do not file an application unless you are willing to face an immediate PAI.” The contract manufacturing organization (CMO) provides the “risk-free” alternative to solve this dilemma.

Contract Manufacturing Facility and PAI
Pharmaceutical firms are well aware of specific areas of activity that are either non-core to the ongoing strategy or are not economically viable to retain in-house. This is why there has been a significant growth in outsourcing. The outsourcing strategy allows pharmaceutical companies to convert fixed costs to variable costs. The potential for increased revenue and cost savings is driving the use of contract manufacturing.

Contract manufacturing organizations have the advantage of possessing the facility, systems, technology and personnel to offer to the prospective client. FDA requires the industry to provide evidence that the firm knows what it is making and knows how to make it. As has been seen time and again, the first objective of the PAI program is to assure that the facilities listed in the application have the capabilities to manufacture, process, package and provide adequate analytical controls according to the cGMPs.

The presence of an outsourcing organization in a product launch plan offers several advantages to a pharmaceutical company. The outsourcing facility will be able to provide a functioning cGMP compliant facility and will be capable of providing necessary equipment, trained personnel and know-how that may not be available in the pharmaceutical company.

Pharmaceutical companies must address the concern over loss of control to the outsourcing organization, as process know-how and in-house expertise become the province of the CMO. However, the benefits of outsourcing outweigh these downside considerations. For a NDA product, product launch timing and business considerations may cause a company to consider a qualified CMO. An ANDA product or existing product may also be outsourced, in order to free up in-house capacity for a new product.

The major pharmaceutical companies are strategically deciding at the early stage of a product’s life cycle whether the product will be outsourced, even though the long-range goal is to bring the product in-house. Sponsors can start working with the outsourcing organization from the early stages. Phase I through Phase III trials could last anywhere from three to five years. This provides the sponsor company with time to evaluate the outsourcing organization. The quality of the programs, personnel, facility, technical expertise and the general business attitudes can all be evaluated during this period. Thorough knowledge of the outsourcing organization and its business ethics and history of compliance may assure the drug company that, if the facility is incorporated into the NDA or ANDA filing, the prospect of passing a PAI are very high. The drug company can help the outsourcing organization bring itself into compliance.

Sponsors seem to believe that it is easy to demand that CMOs demonstrate a higher level of compliance than the sponsor’s own company. In fact, sponsors are at an advantage when it comes to CMO compliance, because their auditing team, along with an independent auditing organization, can audit the contract manufacturer until such time that they feel the PAI will be successful.

Generally, one should assume that the FDA will review the following during an inspection:

a. Facility and systems validation document (water system, HVAC, etc.).

b. Clinical batch records, stability protocols, stability data and analytical methods against the regulatory submission. This data may or may not be at one location. Some drug companies will carry out the analytical controls in their own facility. If there is more than one facility involved, such as API manufacturing, analytical laboratory, manufacturing or packaging, different PAIs must take place.

c. All analytical laboratories that generated data included in the submission.

d. The batch records for stability lots, biobatch lots for manufacturing of the bulk, new drug dosage form (The process validation data is not required for U.S. PAI. However, before marketing the product, the complete process validation data is reviewed by the FDA in an additional inspection.).

e. The validation protocols; i.e., cleaning, computer and methods validation.

f. Development report.

g. Equipment installation and operational qualification data for each piece of equipment in the submission.

h. Validation data for any reprocessing filed in the submission.

i. Sufficient stability data to support the expiration date.

j. Change control.

k. Investigations/deviations.

l. Control of documents.

m. Standard Operating Procedures (SOPs), from receipt of raw material to warehouse distribution.

Regulatory and legal issues are also involved when a drug company uses a CMO. The CMO must comply with cGMPs. Also, the drug company must consider the CMO as an integral part of the drug application and must include the same information for the contractor’s facilities that it does for its own. The CMO shares responsibility for following all the steps necessary for gaining approval for the application.

The PAI of a CMO facility is a true partnering of resources. The drug company brings the knowledge of the product, analytical methods and performance characteristics of the resultant manufactured product, while the contract manufacturer brings the facility, personnel, technical know-how, equipment and experience of manufacturing under the cGMP.

However, since the potential success of the product in the marketplace is based upon gaining approval from FDA at the contract manufacturing site, it is imperative that drug companies work with a reputable organization. Generally, it can take two to three years between the submission following PAI and the approval to manufacture commercially. The drug company needs assurances from the contract manufacturer that the capacity will be available when the product is approved. This poses a serious financial strain on the contract manufacturer who has the investment of the plant, equipment and infrastructure, while the drug company does not have to bear these costs. Recognizing this fact, drug companies and contract manufacturers are considering a mutually agreeable compensation for keeping the manufacturing capacity available while waiting for FDA approval. The nature of this compensation could be a reservation fee that covers the fixed costs for that product at the manufacturing site.

PAI of Contract Manufacture of API
The FDA’s scrutiny of API manufacturers has been increasing. The biggest issue is facility flaws that can cause product contamination. Most of these chemical facilities were never constructed with GMPs in mind. As a result, common design criteria used for finished dosage form manufacture (such as flow of material from receipt through production, flow of personnel, pressurization of areas so that no cross-contamination can occur) are never considered. Other concerns during the PAI are the water system, poor documentation regarding the equipment qualifications, technology transfer, change control, SOPs and good laboratory practices. As FDA is gradually applying GMPs to the upstream processing of pharmaceuticals, API manufacturing facilities will be required to comply with the same guidelines that the dosage form manufacturers are judged by during the PAI. Therefore, the same consideration should be given in selecting a cGMP compliant contract API manufacturer as one would select the finished dosage form contract manufacturer.

PAI of CMOs in a Foreign Country
The PAI of foreign pharmaceutical facilities are generally product specific. In 1996, the initial “withhold recommendation” rate for foreign firms was 42% versus 18% for domestic firms. However, in 1998, the foreign pharmaceutical facilities fared significantly better (9%) than domestic facilities (20%). There is now a better understanding of GMPs in foreign countries. The availability of consultants and organizations expressly catering to foreign pharmaceutical plants has increased the possibility of passing PAI successfully. The requirements for foreign PAIs are much the same as the domestic ones. Several of these foreign establishments are suppliers of the API. In 1995-96, API firms received about 74% of all the GMP compliance letters that FDA sent to foreign firms. Overall, finished product formulators fared better than API manufacturers during 1995 and 1996; 11% of inspections resulted in noncompliance letters compared with 17% of API inspections. Of all the foreign inspections conducted by FDA in 1996, approximately 90% (258) were PAI, compared to 429 domestic PAIs. Nearly one-half of the warning letters sent to foreign bulk chemical manufacturers during 1996 cited problems with the firm’s stability testing program, which included sample storage, evaluation procedures, number of batches tested, control of labeling and type, amount of supporting data, retesting and out of specification (OOS) results investigations.

Conclusion
Worldwide, pharmaceutical companies are struggling with the competing priorities of lowering costs, rising customer expectations, ever-increasing regulatory burden, and the need to reduce cycle times and minimize time-to-market. Pre-approval inspection of a contract manufacturing facility is a partnering of resources. The synergies of two partners can result in a successful PAI. Irrespective of the contract manufacturer’s lo-cation (whether domestic or foreign) and scope of operation (whether finished pharmaceutical or API) the same issues of GMP compliance must be addressed in preparation for PAI.

The outsourcing organization offers drug companies the unique, low-risk opportunity to launch a product after the successful PAI without making the investment of facility or carrying the full burden of overhead of a finished facility awaiting the approval of the product. Qualified, motivated people working in an empowering environment have always provided a competitive advantage. The outsourcing organization is motivated to see that the product receives approval and succeeds in the marketplace, which in turn results in a win–win relationship.

Validation Requirements

This article is the third in a series of articles on compliance with the electronic signatures/electronic records rule found in 21CFR11. The previous articles summarized the requirements of Part 11 and specifically looked at the high-level, policy SOPs necessary to satisfy the validation requirement as well as requirements and design documentation.

This article will also focus on the validation requirement of Part 11. Here we will look at the specific elements necessary to meet the validation requirements for each computer system for test documentation.


Test Documentation
Following a System Life Cycle model, test documentation is developed based on the requirements and system functionality as defined in the system requirements documentation. The test documentation is used to verify that each requirement and function defined in the requirements documentation has been implemented in the design of the system.

Test documentation covers both hardware and software. The testing of the system is generally divided into three sections: Installation testing verifies that the physical installation of the system meets the defined requirements; Operations testing verifies that the system performs the defined system functionality; Performance testing verifies that the system will operate at the extreme boundaries of limits of the requirements and functionality, i.e., maximum volume and system stress. Installation testing and some form of operational testing are performed on all systems, while Performance testing is used for scalable systems and custom (categories 4 and 5) systems.

First, we must discuss the guidelines for the development of test documentation, defining how to write test cases and what tests are required for each complexity category model. Then, we will define how to document the execution of the test cases.

The guidelines presented in this section for the development of testing documentation shall follow the complexity model presented in Table 1 (p. 54).

Regardless of the complexity of the system, the following sections are required in any testing document.

Header and Footer: The header and footer should follow the format generally used in company SOP documents. For example, headers usually contain standard elements (company name), document type ("Requirements Document," for example), and title of the document ( "Requirements Documentation for LIMS version 2.5.") The footer usually contains at a minimum the page number ("Page 5 of 35.")

Approvals: All requirements documents shall have an approvals section where responsible persons will sign. I would suggest the following persons: the author of the document, the computer systems validation specialist and a member from IT.

Introduction: The introduction is a brief statement of what the system is, what the system does and where it is to be located.

Ownership: The ownership section is a statement identifying the owner of the system. The statement of ownership is written in a generic sense, identifying the department that owns the system and the department manager as the responsible person.

Overview: The overview is a detailed description of the system, indicating what the system is expected to do and how it fits into the operation of the department. If the system described in the requirements document is a replacement for an existing system, a brief description of the current system should be included. Enough detail should be included in this overview to give the reader an understanding of the system and what it does without going into discrete functions.


General Instructions to Testers
This section defines the procedures and documentation practices to be followed when executing the test cases. A further explanation of these procedures and practices are presented later in this document.

Discrepancy Reports: This section defines the procedures to be followed when the actual results of the test do not match the expected results.

Signature Log: This section is used to identify all personnel participating in the execution of the test cases. The person’s printed name, full signature and initials are recorded at the beginning of the execution of the test cases.

References: This section identifies the appropriate reference documents pertinent to the execution of the test cases. These documents shall include the SOP, the appropriate requirements documentation, and the appropriate design documentation.

Prerequisite Documentation: This section lists the validation documentation such as the requirements documentation and the design documentation that is to be in place before the execution of the test cases. The first test case shall be verification that these prerequisites have been met.

Test Equipment Log: This section is a log in which all calibrated test and measuring equipment used during the execution of the test cases is logged.

Test Cases: This section presents the test cases used to verify that the requirements and functions defined in the requirements documentation have been met. Each test case shall test one requirement or function of the system. In some cases, several closely related requirements or functions might be verified in one test case. Test cases shall be written in a landscape page setup using a table format and include the following elements:

• Objective – This is a brief statement indicating what requirement, function or module of the system the test case is intended to verify.

• System Prerequisite – This section describes any previously inputted data or other system status that must be in place to properly execute the test case. For example, when testing system security, users of various security levels may need to be in the system in order to test security levels at login.

• Input Specifications – This section defines any specific input data required to execute the test other than keystroke entries. This may include instrument test data files, barcode files, etc. A specific data file may be identified or the file identified may be generic.

• Output Specifications – This section defines the expected output of the test case other than output to the monitor. The output may be identified as reports, data files, etc.

• Special Procedural Requirements – This section details any special considerations that may be required to successfully execute the test case.

• Test Procedure – The test procedure is setup in a table format with the following column headings:


Procedural Steps – This is a systematic series of instructions to be followed in the execution of the test. These steps should be sufficiently detailed as to allow the test to be duplicated by any qualified personnel without changing the outcome of the test.

Expected Result – For each procedural step, the expected outcome of that step should be defined. The defined outcome should be detailed enough to allow an unequivocal determination of the pass/fail status of the step.

Actual Result – This column is to be left blank and completed by the person executing the test when the step is executed. The actual result of the step is recorded at the time the test is executed.

Pass/Fail – This column is used to record the Pass/Fail status of the test by comparing the actual result to the expected result.

Tester Initials and Date

• Comments – This section is complete following execution of the test case and is used to record any discrepancies or details not captured elsewhere in the test script.

• Test Conclusion – This is an indication of the Pass/Fail status of the test case.

• Tester’s Signature – This section records the signature of the person executing the test case and date.

• Verification Signature – This section re-cords the signature of the person verify ing the test results and date.


Requirements Traceability
Each requirement and function defined or described in the requirements documentation shall be reflected by one or more test cases. Following completion of the test documentation, the requirements documentation shall be reviewed to ensure that each requirement is reflected in the test documentation. The section number of the test case that fulfils the requirement shall be recorded in the second cell of the table in the right margin of the page. This provides a cross-reference between the requirement and the test case and ensures that the requirements are being completely verified.

As requirements of the system change, test cases that no longer have an active requirement shall be voided, not deleted. To void a test case, delete the test but not the section number, then enter "VOID" in place of the text. This prevents sections from being renumbered after a deletion and invalidating the references in the requirements document. This also eliminates the potential for confusion caused by re-assigning a section number previously used for an unrelated design element.


Considerations for Developing Test Cases
Installation Testing
Hardware Installation Testing – Hardware installation test documentation provides a high degree of assurance that the hardware has been installed according to the vendor’s specifications and configured in accordance with the requirements and design documentation for the system. This may include access space, power supply/UPS, network communications, interconnecting wiring/ cabling, ambient temperature, ambient relative humidity and peripheral systems connections.

Software Installation Testing – Software installation test documentation also provides a high degree of assurance that the software has been installed according to the vendor’s specifications and configured in accordance with the requirements and design documentation for the system. Hardware installation testing must be performed before installation and testing software. Software installation testing applies to all software components that are a part of the system including operating system software, network and communications software, OEM software and custom software. It should also include virus checking, verification of required drive space, RAM space and drive configuration, software version numbers, security access for installation and operation, directory configuration, path modifications and any system parameter configuration.


Operational Testing
Operational test documentation provides documented evidence that the system fulfils the requirements and functions as defined on the requirements documentation. Each function described in the requirements documentation shall be tested independently.

When a function is defined with a specified range of inputs or range for a data field, that function shall be tested at each end of the range. For example, if the range of acceptable inputs is 1 to 5, the test case shall challenge the functions using inputs of 0, 1, 5 and 6, with 0 and 6 expected to fail.

Test cases shall also test to verify that illogical inputs are not accepted. For example, test cases shall challenge a date function with non-date inputs, or a numeric field with non-numeric characters.

For COTS applications, many times the vendor will supply the test cases. These may be used in lieu of test cases developed in-house. There shall be a documented review of the test cases provided by the vendor relative to the functional documentation to ensure that the vendor test cases are sufficient. For applications where vendor-supplied test cases are used, requirements for the various functions of the application shall not be required, provided there is documented evidence that the vendor has followed a validation methodology.


Performance Testing
Performance testing ensures that the system shall stand up to daily use. Test cases during performance testing shall verify that the system can function properly during times of high user input and high data throughput.

Performance testing is not always applicable. For systems with only a single user, stress on the system is inherently limited. Performance testing is usually executed on complex systems with multiple inputs and outputs as well as network-based systems.


Test Execution
Before the start of testing, all personnel participating in the execution shall enter their names, signatures and initials in the signature log of the test documentation.

Once execution of a test case is started, that test case must be completed before moving to the next test case. An exception to this would be if the test case fails, the failure is noted and the next test case is started. Execution of the entire set of test cases does not have to be completed in one sitting, though once testing begins, the systems may not be altered. Any failed tests shall be recorded and testing shall continue unless the failure prevents continuation. If testing must be discontinued in order to correct any issues in the system, then all tests must be re-executed.

As test cases are executed, information shall be recorded neatly and legibly in black ink. Sign-off and dating of the test case shall occur on the day that the test case was executed. Mistakes made during execution of the test cases shall be corrected using a single strikethrough, so as not to obscure the original data. Any corrections made in this manner shall be initialed and dated by the person making the correction.

Errors in the test script shall be corrected using a single strikethrough so as not to obscure the original data. Any corrections made in this manner shall be initialed and dated by the person making the correction. Any corrections made to the test case during execution shall be justified in the comments section of the test case.

Completed test forms shall not contain any blank spots where information might be entered. If an item does not apply to the current test, the tester should fill in a ‘N/A’ followed by an initial and date. Completed tests are reviewed and approved by the Computer Systems Validation Specialist, or designee, who signs and dates the bottom of each approved test page.

Test Failures and Discrepancy Reports
Results of tests that do not match the expected results shall be considered failures. The failure of a single step of the test case shall force the failure of the test case. However, if a step in the test case fails, execution of the test case shall continue unless the failure prevents completion of the test case.

Errors in the test case that would result in test case failure if left alone may be corrected as noted above. This correction must be justified in the comments section of the test case. Steps in the test case where the expected result is in error shall not be considered test failures if corrected. Test failures shall be noted in the test case and documented on a test discrepancy form. The form is then logged to facilitate tracking of errors during system testing.

Upon resolution of the failure, the cause of the failure is examined with respect to the failed test case and any similar test cases. All test cases associated with, or similar to, the resolved failed test case shall be reviewed to determine the extent of re-testing required. This re-testing, commonly referred to as regression testing, shall verify that the resolution of the failed test has not created adverse effects on areas of the system already tested. The analysis of the testing shall be documented to justify the extent of the regression testing.

Regression testing shall be executed using new copies of the original test script to ensure that the requirement of the system is still being met. In some instances, resolution of the failed test requires extensive redevelopment of the system. In these cases, a new test case must be developed. In either case, the failed test shall be annotated to indicate the tests executed to demonstrate resolution. The additional tests shall be attached to the discrepancy report. This provides a paper trail from the failed test case, to the discrepancy report and finally to the repeated test cases.

Test Documentation by Complexity Model

Test documentation varies with complexity category. Com-plexity categories are defined in Table 1 above.

Category 1 – Operating Systems: Category 1 systems are local operating systems and network systems. These systems provide the backbone needed by all other systems to operate. Due to widespread use of these applications, they do not need to be tested directly. As these systems are the base of other applications, they are indirectly tested during the testing of other applications.

Category 2 – Smart Instruments: Category 2 systems shall be tested following the requirements and functions listed in the requirements documentation. All sections of the testing document as defined in the section "General Consideration for Developing Test Cases" listed above shall be included in the test document for Category 2 systems. Installation and Operational Testing shall be executed. The complexity of the test cases should be commensurate with the complexity of the system. Performance Testing is not required.

Category 3 – COTS Applications: All functions and operations embedded by the manufacturer of the COTS do not need to be tested. Only those functions and operations used by the applications developed in-house require testing.

Category 3 systems shall be tested following the requirements and functions listed in the requirements documentation. All sections of the testing document as defined in the section "General Consideration for Developing Test Cases" listed above shall be included in the test document for Category 3 systems. Installation and Operational Testing shall be executed. The complexity of the test cases should be commensurate with the complexity of the system. Performance Testing is not required.

Category 4 – Configurable Software Systems: Category 4 systems shall be tested following the requirements and functions listed in the requirements documentation. All sections of the testing document as defined in the section "General Consideration for Developing Test Cases" listed above shall be included in the test document for Category 2 systems. Installation and Operational Testing shall be executed. The complexity of the test cases should be commensurate with the complexity of the system. Performance Testing should be considered if the system shares data on a network.

Category 5 – Fully Custom Systems: Category 5 systems shall be tested following the requirements and functions listed in the requirements documentation. All sections of the testing document as defined in the section "General Consideration for Developing Test Cases" listed above shall be included in the test document for Category 5 systems. Installation, Opera-tional Testing and Performance Testing shall be executed. The complexity of the test cases should be commensurate with the complexity of the system.


Following a System Life Cycle model, test documentation verifies that all requirements have been properly met in the design phase of software development. Future articles will follow the SLC model into the next phase of software validation: change control.

Packaging Process Validation

Packaging process validation is often supplemented by 100% inspection online. Many firms take the approach that a 100% online inspection is the way to go. Even today, many companies have inspectors set up offline to sort out or rework unacceptably packaged product. Often, process variables are not adequately studied or the process is not observed to “nail it” through process validation. The following approach used by a large pharmaceutical company to validate the blister packaging process may shed some insights on how Design of Experiments (DOE)—prior to packaging validation—can help.

This case study is about an OTC product. The product launch date was set in stone; the marketing managers were even talking about pre-launching the product to select large-scale retailers. The operations team was under tremendous pressure to finish the process validation and pre-launch activities of this OTC product. The product was a coated tablets, the packaging put-up was a carton with three blister cards, each card with eight tablets per card, making it a pack of 24 tablets.

The team consisted of a Packaging Engineer, an Operations Engineer, a Production Manager, a Quality Engineer and a Project Manager. Traditionally, the company validated the packaging process by optimizing the packaging process variables and making three runs. A statistically valid sampling plan would be implemented and sample packages would be tested per the finished product specifications. In most cases, this approach worked. But this was not one of those usual projects.

Let us look into the specifics. The package design required the patient to peel the foil by holding on to a center tab. See Figure 1, which shows an example of the four-way notch at the center tab. Since the product was geared towards the elderly, the package design presented some unique challenges. A trial run was performed and some samples were shown to marketing. While the overall package quality in terms of appearance and integrity was fine, Marketing thought that the package was simply too hard to open.

The team decided to establish optimum packaging process parameters using Design of Experiments (DOE), prior to conducting packaging process validation. In “old school” scientific experimentation, people are used to conducting an OFAT experiment. What that means is that the process is studied by simply by changing One Factor At a Time (OFAT). This method, while successful in some cases, is almost always time consuming, costly, and does not guarantee that all the parameters have been optimized.

The team decided to do the more methodical DOE ap-proach, where one changes multiple parameters at a time to understand the process output.

There are many schools of thoughts and styles for conducting such sophisticated DOE trials. One way is to conduct a “Full Factorial” experiment. That is, the process is run for many trials at all the possible extremes of each variable. Such experiments are essentially an OFAT multiplied many times over. One can collect a large amount of information about the process, but the quality of the information depends on the number of trials one runs at each set-up parameter. Although it may seem counterintuitive, one can design a set of trials that is not a full factorial experiment, and still collect adequate information. The obvious justification for this is resource savings. Here’s a simplified example:

Let's say there are two variables (A & B) that impact product quality. And let’s say that the two extremes of each parameter are defined as + and – signs. This means the process can be run in four possible combinations as follows:

A+ B+
A+ B-
A- B+
A- B-

One can then run the process at each of these settings and collect results. None of these may be optimal, but one can get some information about how the process behaves at these extremes. (The purpose of this article is not to provide an extensive treatment of statistical analysis, but to give a flavor of how experimental trials can be constructed.)

In the present case, before these trials were designed, the team brainstormed on different variables and decided to list all the significant ones. Here is a simplified list of all the potential parameters that would affect the package quality:


Materials:
Process Variables:
Determines the dwell time of the blister card on the sealing plate.
This is measured as the force with which the blister card is formed by combining the PVC with the foil-backing. The force is applied by a plate by a rotating cylinder.
Temperature of the knurling plate — a critical parameter for the overall process can be raised or lowered, but once reached, it remains constant. To get to a different temperature, the line needs to be stopped until the temperature is reached to the new requirement.

One of the significant questions was: What is the one thing that the team is trying to solve? Marketing only gave one clue, that the package should just be easy to open. That is a very broad statement. How can one determine what is easy to open? What may be easy for one person may be difficult for another. There is also the question about technique, of how each person holds the blister card before opening and how one peels the backing. So the team decided to establish a scale of difficulty-to-open. The scale was established as 1 being too difficult, 5 being the best possible, easiest to open without impacting product seal integrity, but even this scale would differ among different people. Finally, the team took some of the samples of the trial runs and had a random group of in-house consumers decide on the technique (per the instruction on the blister card). Once the technique was finalized, about 10 people were asked to peel blister cards and define the difficulty scale. The results were averaged and, with some statistical and some empirical observations, a set of ‘standards’ was created for each notch in the scale (1-5). These ‘standards’ were set aside to be used for comparing the process outputs from each experimental trial.

In technical terms, the process output or the quality para-meter that is checked after running an experimental trial is called a response. When results of each trial are graphed statistically, one gets a ‘response curve,’ which is a sort of continuum that shows the impact of various parameter levels on the response. Within statistical bounds, one can extrapolate or predict the response of a combination of process parameters simply by looking at the graph.

Based on the parameter list, the team decided to set combination of the trials. All the possible combinations are as follows:

Temperature
High
Low
Seal Pressure
High
Low
Line Speed
High
Low

As you can see there are six possible combinations:

Temperature Seal Strength Line Speed
High
High
High
Low
Low
Low
High
Low
Low
High
Low
High
Low
High
High
Low
High
High


Essentially it is a 3! (Factorial) experiment i.e. 3 x 2 x 1 possible combinations. But is running this one set of trials enough? A statistician will tell you no. One can get some information by running these six trials, but one cannot have a high level of statistical confidence in the results. The team decided to run all six of these trials in a random order. Each set of trials was run three times, for a total of 18 trials. The number of trials was decided after a statistical review and a formal cost-benefit analysis performed by the operations team and the Quality Engineer. From each trial, a set of about 100 blister cards were sampled. About five people ‘opened’ these 100 samples from each trial and rated the difficulty to open on a scale of 1-5. These results were statistically processed to calculate their averages and variance. The results were tabulated and statistically graphed.

These three variables, we note, are continuous, by which we mean that one can run the process having the variable at any point within the extremes. There are also categorical variables, which can only be run at a set level. For the purpose of the experiment, the process was run at only high and low levels, but the response curve can show with graphical detail how the process will behave at intermediate points.

This approach—conducting a DOE prior to committing to a full-scale packaging process validation—can save a lot of problems down the road and also improve process understanding.

Some readers may think that this is way too much of a hassle to go through before process validation activities, and one might even argue that this process should have been optimized much earlier. Management is always driving to reduce costs and restrict resources. All the line time, material and support personnel costs add up to a hefty bill. How can one convince management that this is a worthy project? The short answer is that everyone must be engaged. In terms of the overall project, it is truly the Project Manager’s role to challenge the team about minimizing costs and assuring success. This team had a competent Project Manager who did not baby-sit the project but held regular formal and informal meetings on an individual and team basis. He would visit the production line at odd hours to see how he could smooth out any administrative or resource issues. Additionally, this project was chartered formally with all the checks and balances. The costs of doing the project were clearly offset by the costs of not doing the project. Marketing made the case of cost of product complaints, loss of revenue, and competitor’s advantages. When the numbers were charted and compared, Senior Management did not hesitate and gave a go-ahead. Contingencies about launch delays were also planned, to the dismay of Marketing. The team members managed expectations quite well. Every department head was fully engaged. The project manager updated the progress on bulletin boards.

But still the question remains, why did it come down to the eleventh hour to start this project? The problem was that, when the product was originally designed, no one took into account the impact of various process variables on the ‘ease of use’ aspect. This customer requirement figured in late in the game, when marketing actually tried to open the package. One of the major lessons learned was to have all customer requirements figured out. In this case, the dimensional and other quality aspects of the blister card — such as appearance and seal integrity, were established, but the ergonomic issue was not captured.

Conducting DOE is not an easy thing. Running the trials and tabulating the results may actually be quite fun, but before one goes about conducting these experiments, a lot needs to be thought out. Thinking this through requires a lot of technical/process expertise and statistical knowledge. A DOE project will require the experimenter to make a set of assumptions. Failure to make the right assumptions can potentially fail the experiments. For example, if an important variable is ignored and not included in the trials, the results may show a set of optimal parameters that won’t work in real life. One can also be blinded by making strictly intuitive ssumptions; the whole idea of experimentation is to provide a laboratory setting. To that end, a good Quality Engineer with a solid statistical understanding can help set the right course.

The reader must be wondering by now about the results of the trials that we conducted. Well, the results showed with graphical clarity and with a high level of statistical confidence that temperature was not a huge factor, but line speed and the seal strength had significant impact on ‘ease-of-use’ response. Additional confirmation trials were run to prove that the optimized setting do in fact produce predictably good product. After that, packaging validation was a cinch. The team was applauded for its hard work and the product launched on time.

We have simplified a lot of information to make this article free from statistical jargon, as it was far beyond its scope. But the lessons of this story are worth noting:

Packaging process validation is not just a regulatory compliance exercise; rather, it is a customer-centric activity.
Data-based decision making saves time and improves the chances of a successful validation.
Design of Experiments can be a very powerful tool to understand your process and to predict effect of various variables on the process outputs.
Projects must be chartered formally to assure success. Team members must be selected carefully and the Project Manager must keep the project moving.
Senior Management must fully trust the team and provide the agreed upon resources.
Contingencies for failure must be planned and what-if scenarios must be fully understood.

It can be said that a competent, motivated team, a worthy project, and sound management can solve any packaging validation problem. END


:
While a full factorial experiment was conducted in this case study, there are many statistically sound ways of conducting experiments. For example, there are many ways to conduct partial factorial experiments. One can also study the impact of several parameters by conducting screening experiments. The reader is encouraged to study the subject. One recommended book to get a feel for the subject is The Experimenter’s Companion by Richard B. Clements – ASQ Press

Aseptic Process Validation

Is a new FDA guidance imminent?



by Tom Spurgeon



What are the regulatory pressures facing aseptic process validation today and what will they be like over the next few years? An inquiry into existing literature and with current industry personnel reveals a corner of the pharmaceuticals industry driven by a lattice of suggested improvements, a constant hum of activity and improvements that fight to keep pace with general industry trends and emerging technology. Those working in aseptic processing validation must consistently look five years ahead and five years behind, at rules and informative processes and market realities, all of which play off one another like so many strings on a musical instrument. With an important FDA guidance revision just now beginning its long fade into routine and a brand new one described as imminent, aseptic processing and its regulatory outlook is at the forefront of pharma and biopharma business plans.

It's worth noting that the core guidance revisions for aseptic processing validation are still new. "The reason it's a hot area is that we had the aseptic processing guidance that was revised in 2004," said Hal Baseman, chief operating officer and a principal partner at Valsource.

Maurice Phelan, director of Pharmaceutical Technology, BioProcess Division at Millipore Corp., noted that newer statements are driving much of the attention: "The one thing that's gotten everybody interested, and sort of sparked a lot of interest in this subject over the last say year and a half, is the major statements by particularly the FDA about the need to change the way we manufacture sterile products."

Mr. Baseman added, "In September of 2004, there was a revision of the aseptic processing guidance. That resulted in a lot of discussion around validation of aseptic processing and things like that. It's always been a hot issue, an important issue, if you look at it from a risk management perspective. It's certainly a process that gathers a lot of attention."

Mr. Phelan sees the 2004 guidance as even more important in context. "I think it's the 2004 guidance, which was long awaited, but is also the strategic plan that the FDA has laid out, all of the concepts that are embodied in their GMPs for the 21st century initiative. All of the high-level sorts of concepts and aspirations that they have that are laid out in things like the Critical Path Initiative. And then there's the 2004 aseptic process guidance, when it's considered in the context of quality by design, design space concepts, all of the buzz in the industry around efficiency and manufacture, things like process analytical technologies -- when you consider all of those as contributors, then I think the buzz that's around aseptic processing and next generation manufacturing is a result of all of those together, and the context they have for whatever kind of manufacturing you do, whether it's biotech, or classical pharma-type manufacturing. It all depends on your interpretation on what it means to you."

The 2004 revision was the first major one since 1987, and therefore drew attention not just for the new standards it suggested, but for how the revision reflected modern industry practices. The result was a wave of attention to such issues that continues unabated. There are at least two major conferences this autumn that promise discussion of the subject, and specific classes on techniques involving aseptic processing and its validation that are filled weeks in advance. Mr. Phelan noted that there is genuine change reflected in the approach to process validation, within the hierarchy of validation.

He said, "Historically much of the body of work that would be called process validation wouldn't necessarily differentiate between that which was super-critical and that which was a required component but had variability that the process could tolerate. Intuitively the FDA is saying it's not just practical. Intuitively, if you've thought through a rationale that allows you to rank the criticality of unit operations in your process, then there should be a corresponding validation in your unit operations that's increasing in focus and scientific content as you go up the criticality scale. "I've heard an FDA inspector say, ‘Say what you're going to do. Prove that you can do it. And then when you get into manufacturing, do what you say you do.' That's a fairly straightforward statement for these guys to make."

In making its guidance revisions, the FDA gathers information from industry sources and then, once compiled, releases it back, causing a re-affirmation of the industry's best practices distinct, in its way, from standards the FDA might apply to drive companies into certain practices. At one meeting in 2002, the FDA's Advisory Committee For Pharmaceutical Science heard from several industry leaders and its own speakers on a variety of subjects related to aseptic process validation, including container-closure and sterile isolators. As Mr. Baseman put it, "Because we had an opportunity to comment extensively as the FDA allowed us to do [for the 2004 guidance], it became a reflection of what the industry was doing."

That give-and-take continues into the field. Said Mr. Phelan, "I heard this from the FDA as recently as last week: If you want to interact with them, and you're prepared to think about applying some of these next generation concepts, than they want to engage you." This is a change from times past, he noted. "Historically the FDA would have said, ‘Our door is open, and nobody's coming to talk to us. It's a one-way affair for us, and we have no option but assume a worst-case scenario. The only opportunity we have to share information is in the limited capacity of inspections or audits or reviews.' Now they're saying, ‘We have to change the way we do business. It's our view that you, the manufacturing community, need to look at how you manufacture and look at these types of areas.' Quality by design is the classic example of what they'd like to see.

"They've put programs into place," he added. "They have a pilot program that's gone on for the last 12 months for the review of new drug applications, where they've invited people to participate in basically a risk-based construct for the CMC sections in their new drug application."

The Guidance revision not only provides a platform for understanding the FDA's expectation and current industry practices, it also serves as a spur to science by offering up its own set of ways to approach certain problems while fostering from related organizations more up-to-the-minute, specific technical solutions.

With the FDA's more general efforts starting in 2001 to implement GMPs "for the 21st Century" -- itself two decades since the last similar effort -- came an emphasis on risk analysis. Risk analysis became the tool through which managers began to approach the validation of their aseptic processing techniques.

Mr. Baseman explained the general process as it has an impact on a facility's approach to their processing procedures: "Most biological contamination comes from people. So anything involving human intervention is going to be a riskier step. If we're doing an aseptic process test, let's say there's a step in there where somebody has to add a component manually, like a stopper. That becomes a riskier step. If we can eliminate that step by having some automated system to do that, then we eliminated and improve the process. That pushes us towards using isolators rather than conventional filling lines." The prioritization that comes with risk-management engenders a step-by-step vetting of the process validation. It puts emphasis on key points such as filtration, and then works its way backward to elements with less of a risk. As risk-management works its way to and then through those industry agents that have yet to fully embrace that approach, their use should become more and more routine.

This is just the way the FDA wants it, said Mr. Phelan. "Classically, validation exercises have been very, very document-heavy exercises. The FDA are now saying that we think there's a very practical approach to be taken in addressing all of the validation that needs to be done in a manufacturing process, assessing what the risks and/or overarching benefits are to putting so much effort into that enormous body of work, and then maybe thinking about a different way of justifying the amount of focus you put on in respect to validation, exercises based on their risk to your program."

Despite the fact that ideal sterilization technique is terminal, or heat-based, the market should drive more and more companies into aseptic processing. As most are quick to point out, terminal sterilization is a poor technique to apply to unstable products such as those represented by protein-based drugs. Aseptic processing places a specific emphasis on filtration as the last process performed to destroy organisms or contamination within a product. "Filtration would be where you would take the product, put it through a .2 micron filter and then fill it under very controlled conditions, in a clean room, perhaps in an isolator or perhaps in a conventional clean room but one with a lot of controls to keep the contamination out of the product," said Mr. Baseman. "Because there will be no subsequent step to destroy those organisms. That's why filtration is of interest related to aseptic processing."

With technology, market concerns and the introduction of new techniques and practices all driving interest in aseptic processing and its validation, one might think of the regulatory backbone as one of pressure and punishment. Actually, the opposite seems closer to the truth. Mr. Baseman praised the FDA for its ability to solicit commentary when preparing its guidances, both from individual players and major industry organizations like the Parenteral Drug Association (PDA). Not only does this give them a wider array of knowledge to use, the process settles industry players for whatever changes are to come. "I believe it's rare for the FDA to come out with something that's a big surprise," said Mr. Baseman. "For the most part what happens is that guidance gets issued that reflects what the FDA has been talking about and what the industry has been doing.

"I think there's an anticipation, but I don't think people are sitting there saying, ‘Maybe we shouldn't do any process validation this year because everything is going to change.' I don't think that's the case. The FDA has done a good job indicating where it's heading with this. They certainly put out some pretty good information in their initiative documents. There was a CPG that came out I think last year, but that CPG -- and that's their internal guidance document -- talked about what the agency would internally be looking for when it reviewed submissions. So if you read that, you kind of understood what the Agency is looking to do."

Groups like the PDA provide further support by issuing technical reports following guidances and standards, reports that provide a very specific way of meeting required standards, to be accepted, used or even refused, and make more clear the science of what's being done, away from purely regulatory motivations. For instance, PDA Technical Report #42 deals specifically and in what is described as a "practical" fashion with Process Validation in terms of protein manufacturing.

This system of multiple supports and reinforcements sets the stage for a revised guidance from the FDA for processing validation. Mr. Phelan characterized such revisions as "imminent." As to what that revision will entail, Mr. Baseman opined, "I think it may have something to do with new techniques. There's so much new technology that's coming out now, and I think it's important that the PDA weigh in on new technology, things down the road: new technologies for monitoring and so forth."

Mr. Phelan thinks the emphasis will be on the principles driving multiple solutions. "What I would expect is that it will contain all the intellectual components that one would classically associate with process validation and then it will have loaded on top of those good validation practices the concepts of design space, critical process parameters, risk-based decision-making and then practical validation approaches -- a rationale that says I understand what drives my process and I understand the critical parameters I need you to control and I need to validate.'"

As more companies are driven to work with drug forms that resist terminal sterilization, those that embrace GMPs and a risk-based outlook should find strong support in terms of aseptic process validation techniques, applied to steps ranging from filtration to use of isolators to air flow, that match the criticality of each phase to their overall function. Look for future guidance and technical papers to build on rather than replace the general outlook, at least until it becomes routine, as all former hot topics must sooner or later.

Pharmaceutical Validation Documentation Requirements

Pharmaceutical validation is a critical process that ensures that pharmaceutical products meet the desired quality standards and are safe fo...