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An Update on ICH Guideline Q8 – Pharmaceutical DevelopmentFDA Advisory Committee for Pharmaceutical

Science: 5 Oct 2006

Dr John C BerridgeSenior Regulatory ConsultantPfizer ISPE Vienna Congress 2006

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Presentation Outline

Background to Q8 Experience of Q8 to date Implications of Q8 Future strategy for Q8

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July 2003: An ICH vision

Existing Existing GMPGMP’’ss

Quality by Design(Pharmaceutical

Development)

Quality Risk Management

The Regulatory Quality System

Our vision: The future Pharmaceutical Quality System

Quality Systems

Quality Systems (Q10)

For companies with :1. Good design and

control strategies2. Good Risk

Management strategies3. Good Quality Systems

Quality Risk Management

(Q9)

Quality by Design

(Q8)

Reduced regulatory burden:

• Reduction of submissions on changes/variations

• Inspection of quality systems

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Q8– an opportunity for change

Empirical

Data Driven

Retrospective

“Test to document quality”

Acceptance criteria based on limited batch data

Variability not understood and avoided

Systematic

Knowledge driven

Prospective

Science and Risk based

Acceptance criteria based on patient needs

Variability explored and understood (Design Space)

Q8

Traditional Future

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On July 20th 2004 you were told Q8 could deliver:-

Product quality and performance achieved and assured by design of effective and efficient manufacturing processes

Product specifications based on mechanistic understanding of how formulation and process factors impact product performance

An ability to effect Continuous Improvement and Continuous "real time" assurance of quality

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The EWG has delivered the core guideline

Part 1Core document Baseline expectationsOptional informationRegulatory Flexibility

Q8 is a 2 part guidelineQ8 is a 2 part guideline

Step 4: Nov 2005

RevisionAnnexes relating to specific dosage forms (as Q6a)References to use of risk managementFocus on guiding towards Desired State

Drafting underway

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Presentation Outline

Background to Q8 Experience of Q8 to date Implications of Q8 Future strategy for Q8

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We have recognised Q8 encourages a new development paradigm – Quality by Design

Target Product

Profile

Define product intended use & quality targets (wrt efficacy & safety)

Product/ Process DesignSpace

Through hypothesis testing, create scientific understanding of product and process. Identify ’critical to quality attributes’ and establish multi-variate ”Design Space” that assures Quality

Control Strategy

Define control strategy based on Quality Risk Mgmt & Design Space leading to control of quality relevant to safety and efficacy.

Product/ Process

Dev.

Incorporate prior knowledge, Risk Assessment, DoE and PAT to create New Scientific Knowledge,

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To provide a product that consistently meets their needs….

..we need to manufacture by a process that is well understood,

robust, but adaptable…

… to the variability of input materials-API, Excipients etc

= DESIGN SPACE

Quality by Design starts with the Patient, delivers consistently to the patient, but welcomes variability!

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Design Space: 3 key concepts

Design Space: the multidimensional combination and interaction of input variables (e.g., material attributes) and process parameters that have been demonstrated to provide assurance of quality.

Working within the design space is not considered as a change. Movement out of the design space is considered to be a change and would normally initiate a regulatory post approval change process.

Design space is proposed by the applicant and is subject to regulatory assessment and approval.

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Q8 applies throughout product life-cycle

Product Development

Design quality product & process to consistently deliver intended performance.

Knowledge gained from development studies & manufacturing experience provide scientific understanding to support the establishment of the design space, specs, & manufacturing controls.

CommercialManufacture

Risk-based regulatory decisions (reviews and inspections); Manufacturing process improvements, within the approved design space, without further regulatory review.Reduction of post-approval submissionsReal-time quality control, leading to a reduction of end-product release testing

TechnologyTransfer

Demonstration of greater understanding of pharmaceutical and manufacturing sciences can create a basis for flexible regulatory approaches.

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Industry is capitalising on Q8

NDA/CTD submissions are changing‘Here is my science, here is my manufacturing scheme which was developed through my science, here is how they link together’

– M Kovalycsik - Wyeth

FDA pilot programDesign Space submissions

Continuous process verification– Compliance policy 7132c.08

Already Q8 is delivering value to the Industry, the Regulators and, ultimately, the patient

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Presentation Outline

Background to Q8 Experience of Q8 to date Implications of Q8 Future strategy for Q8

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Understanding the full implications of Q8 is not easy

The Q8 EWG believes the core guideline needs exemplifying

What is Quality by Design?What’s the difference from the way pharmaceutical development has been approached and described until now?Can we help in distinguishing baseline or ‘minimum’ from enhanced?How exactly does the applicant describe the Design Space?

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Q8 challenge example – What is Design Space?

Traditional Method:

Carry out the reaction at pH 2-5 and between 30 and 60C

= ‘Proven Acceptable Ranges’

5.0 pH2.0

60C

30C

How do we describe the <criterion>, relationship and associated control strategy?

Design Space:

Carry out the crystallisation to create particles at size/shape <criterion> varying the temperature, stirring rate and super saturation according to the relationship:

Size = f(temperature) + f(stirring) + f(super saturation)

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Wider implications of Q8 development

Can we clearly articulate what we mean by Quality by Design and understand its implications for both the Industry and Regulators?

As we complete revision of Q8 should we add a glossary of key terms, perhaps illustrated through examples?

How should we address API development & manufacture for both chemical and biotech? Draft concept paper for NCE API available Biotech paper not endorsed by ICH

– Critical we assess implications of “Quality by Design”

Q8 is impacting the way we define specifications (Q6A & Q6B)

There may be other things needing consideration E.g. analytical methods

These issues likely to be raised at ICH quality strategy discussion

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Presentation Outline

Background to Q8 Experience of Q8 to date Implications of Q8 Future strategy for Q8

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Progression of Q8

EWG has changed its focus for the revision from parenterals to solid oral dosage forms

Because it provides the greatest opportunity (lots of background and expertise) and is most common dosage formWhen oral solids agreed, we will address the other types of dosage form

Illustrate QbD principles Examples drawn from EFPIA mock P2 documentEnsure that we are clear on Design Space

Step 2 date hard to predict

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Progression should continue since Q8 is positively impacting Industry and Regulatory Practices

Science-based (Quality by Design) approaches will bring needed medicines to patients in more robust and effective way and unlock the innovative potential of the industryRegulators are responding supportively

FDA: • Development of elite teams comprising investigators, analysts and compliance

officers from field and CDER organisations : capable of making judgements about a firm’s risk management programmes, product and process knowledge, process capability and robustness of quality systems.

• Considering making revisions to its post-approval change reporting regulations (21 CFR 314.70) to accommodate more "regulatory flexibility" for drug makers operating within their pre-disclosed design space

– J Clark 28-8-06

EMEA: Revision of Variations Regulations• “We have come to the conclusion that the concepts laid down in these

guidelines – also taking into account the ongoing work of Q10 – could not be properly implemented in the EU without amendments to the Variations Regulations”

G Lalis, EC; 16-3-06

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Ultimately, it’s all about structured KNOWLEDGE: this links with Q10

TPP Prod/Proc Design ControlDevelopment Space Strategy

Clin Dev

TechTransfer

CommProduction

Knowledge

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Q8, Q9, Q10 – the opportunity

To deliver the ICH Vision and modernize Pharmaceutical Manufacturing and associated regulatory processes……….

Existing Existing GMPGMP’’ss

Quality by Design(Pharmaceutical

Development)

Quality Risk Management

The Regulatory Quality System

Our vision: The future Pharmaceutical Quality System

Quality Systems

Quality Systems (Q10)

For companies with :1. Good design and

control strategies2. Good Risk

Management strategies3. Good Quality Systems

Quality Risk Management

(Q9)

Quality by Design

(Q8)

Reduced regulatory burden:

• Reduction of submissions on changes/variations

• Inspection of quality systems

BOTH Industry and Regulators need to work together to change the current paradigm and mindsets……..

– Q8 / Q9 / Q10 providing a ‘once in a lifetime’ opportunity– Let us progress the concepts and guidelines with enthusiasm and optimism!