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Consortium activities on developing a strategy for the implementation of Modern Microbiological Methods in
place of traditional testing for new products
• Karen Capper Astra Zeneca • Paul J Newby , Microbiology Modernisation Lead, GSK R&D
Outline
• Introducing the Microbiology Modernisation Cross-industry Consortium (MMCC) • The GSK experience post Pharmig 2017 with MHRA Innovation office
• Challenges for implementation in place of traditional methods • Modern methods, potential applications and readiness levels • Implementation strategies
• The AZ experience • MHRA regulatory engagement and the benefits of early engagement and using the
innovation centre • Consortium contact details
MICROBIOLOGY MODERNIZATION CROSS -INDUSTRY CONSORTIUM (MMCC)
THE PURPOSE OF THE CONSORTIUM (MMCC) IS TO CATALYSE TRANSFORMATIONAL CHANGE IN
MICROBIOLOGY TESTING BY ESTABLISHING STRATEGIC PARTNERSHIPS TO ENABLE IDENTIFICATION AND
INDUSTRIALISATION OF STANDARDISED TECHNOLOGY PLATFORMS AND WAYS OF WORKING.
MMCC Key areas of collaboration and vehicle for change include, but are not restricted to:
• Foster collaboration and communication between
key stakeholders in the precompetitive space
• Share knowledge on new technologies
• Develop best practices
• Speak with a united voice to the regulators to
stimulate acceptance of new validated
technologies
• Speak with a united voice at conferences and
industry fora to provide direction to the suppliers
in the development of their technologies
• Develop an effective business case tool
• Progress similar innovations with comparable
benefits profiles
• Develop strategic alliances with key suppliers and
institutions
• Share insights and input on implementation of new
technologies
• Create sub-teams to progress individual projects
• Centralise validation protocols for new
technologies
CONSORTIUM AREAS OF INTEREST
• Drivers for modernisation of microbiology methods
• Challenges for implementation in place of traditional methods
• Modern methods, potential applications and readiness levels
• Implementation strategies
• MHRA regulatory engagement and the benefits of early engagement and using the
innovation centre
• Consortium purpose, status and activities
Modernisation of Microbiological Testing in GSK
Paul Newby – Future Analytical &
Control Technology (FACT)
Alice Laures - FACT
Philip Butson – Quality Assurance
Sandra Kite - CMC Regulatory
Julian Kay – Quality Assurance
MHRA 16th Aug 2018
Confidential
RMMs already in use (but needs more uptake)
Regulators are keen to support innovation
Help the regulator to understand
Caution
Be careful what you ignore
Still need the right knowledge
Additional tool in the tool box does not necessarily replace existing tools
Talk to Regulators!
Andrew Hopkins, MHRA senior inspector – Pharmig
conference Nov 2017
Presentation title
Modernising Microbiology Discussion with MHRA Innovation Office,
• Phil Butson, Director, Quality Futures
• Sandra Kite, Director Global CMC Regulatory
• Alice Laures, Manager Future Analytical & Control
Technologies
• Paul Newby, Microbiology Modernisation Lead
• Sarah Gomersal, Pharmacopoeial Scientist
• Andrew Hopkins (via phone), Expert GMDP Inspector
• Nafisa Potrick, Scientific Innovation Lead
• Ian Rees, Unit Manager, Inspectorate, Strategy & Innovation
• Ioana Venet, Pharmaceutical Assessor
Innovation Office, MHRA, Canary Wharf, 16 Aug 2018
• GSK ATTENDEES
• MHRA/BP ATTENDEES
Meeting Aims and objectives
Meeting objectives were :
• To provide the IO with an awareness of the drivers, status and future plans for
modernization of microbiological testing within GSK, including environment
monitoring, and a focus on rapid sterility testing.
• To obtain feedback to help enable the implementation and uptake of modern
microbiological testing technologies.
• Discussion topics
– GSK’s RMM technology roadmap
– Alternative approaches to sterility testing
What did we want to get out of our meeting with the Innovation Office (IO)?
9 Confidential
Introduction
GSK has identified 2 main drivers
• Near/Real time analysis
Real time or near real time microbiological analysis of product quality is the desired state but not possible with
conventional growth-based methods.
• Direct Data Capture (Data Integrity considerations)
Microbiological test platforms with integrated data capture functionality. This is the desired state for environmental,
process and product analysis.
Drivers for modernisation
Confidential 10
These considerations have led to the development of a microbiology testing technology roadmap
which was discussed with the IO and feedback provided.
Guiding Principles Drivers Alignment
Rea
din
ess
Ind
ex*
Standard technology platforms
Dir
ect
Dat
a ca
ptu
re
Rea
l tim
e/ n
ear
real
tim
e
ster
ile p
rod
uct
an
alys
is
Nea
r re
al t
ime
envi
ron
men
tal
mo
nit
ori
ng
Rea
l tim
e /
nea
r re
al t
ime
tro
ub
le
sho
oti
ng
inve
stig
atio
ns
Smal
l Mo
lecu
les
Bio
Ph
arm
Ad
van
ced
Th
erap
ies Network Alignment
Automation
GMP compliant
Data integrity standards met
LIMS compatible
End user driven
Enab
ling
Pla
tfo
rms Growth Direct 2nd Gen
Strong Strong 7
Automated plate readers Strong Strong
6
HVLD (E-Scan 625) Strong Strong
9
RaSTA (ParaDNA & ddPCR) Strong 4
Growth Direct for Sterility testing Strong Strong Strong 6
BacT/ALERT 3D Dual Temp
Strong Strong Strong 9
Microbiology testing - technology Roadmap
HVLD = High Voltage Leak Detection
RaSTA = Rapid Sterility Test Approach
LIMS: Laboratory Information Management System
* On a scale from 1 to 9 with 1 being an idea in academia and 9 being
a commercial instrument
Overview of current main areas of interest – short to medium term
11
Confidential
Sterile products Container Closure Integrity (CCI)
12
High Voltage Leak Detector (HVLD)
Stability Sterility Test Surrogate
• EMA outlined in 2009 that sterility testing should be performed at least at the end of shelf life but it could be replaced by testing of container closure integrity (CCI).
• Substitution of sterility testing by CCI for interim time points has been accepted by some markets but it appears that uptake as an approach is slow.
• GSK is investigating HVLD for CCI as an alternative to Dye immersion/microbial ingress for interim time point testing of steriles due to
– Suitable for wider product range
– More objective end point (turbidity, dye detection)
– Simplification
Q – Does the IO have a view as to why uptake of using CCI for interim stability testing appears to
GSK to have been slow?
Q – What would MHRA specifically need to justify the use of HVLD for interim stability testing?
Q – Would HVLD for CCI be an acceptable approach at interim stability timepoints in lieu of sterility
testing ?
Confidential
Rapid sterile products testing
GSK is using BacT/ALERT for Advanced therapy products and is investigating its use for small molecules sterility testing where membrane filtration is not applicable.
However, our ambition is to use it as our first intent sterility test including small molecules.
Challenges
• Direct inoculation only – sample size restricted to 10ml per canister
• Not a compendial method as yet
• Slow uptake by industry for sterile small molecule release testing – Previously single temp system – GSK use recent dual temperature system
• Equivalence testing interpretations in USP, EP, BP
BacT/ALERT
Q – What would be the appropriate validation requirements?
e.g. would following the USP guidance on equivalence testing satisfy the requirements from EP and
BP? 13
Q – Given the BacT/ALERT is designed as a direct inoculation technique, would MHRA & BP support a
position to use BacT/ALERT for filterable solutions?
Confidential
Innovation Office meeting outcomes
• The meeting provided a very informal opportunity to talk to MHARA and BP
• It was very informative on both sides
• MHRA
– Underlined the importance of cross industry groups in generating more data from more players
– The importance of data integrity and validation in pharmaceutical microbiology
– The need for ongoing dialogue especially in areas not directly involved in regulatory submissions eg.
Environmental monitoring technologies
– The importance of product based justifications for technologies such as BacTalert for small molecule,
filterable products
– Willingness to review but not author experimental protocols for technology innovations
AstraZeneca Approach to the Modernisation of Microbiology
Karen Capper PharMIG Conference November 2018
AstraZeneca’s Main Drivers for Modernisation
• Increased process understanding, knowledge and robustness
• Ability to introduce the engineering technology available to us to
improve patient protection and reduce waste due to batch
rejection
• Reduction in cycle times
• Reduction in time to results
• Reduce in time to batch release or the ability to move stages of
the production process on faster
• Faster supply chains
• Reduce data integrity issues
• Increase sustainability
Product Release Tests
Our diverse range of products means we need a diverse
range of solutions
Challenges of Traditional Methods • Slow • Will only detect a fraction of actual
bioburden • Prone to data integrity issues • Can only respond to an issue/event days
after
Modern Micro Methods Can be; Qualitative Quantitative Identification
Growth Based platforms reduce time to detection of organism, use conventional media, therefore same application that traditional methods are used for can be applied to growth based alternatives
Viability-based use viability stains and laser excitation
Cellular component-based rely on detection & analysis of portions of the cell
Micro-Electro-Mechanical Systems (MEMS)
18
Challenges of Traditional
Methods
• Slow
• Will only detect a fraction of
actual bioburden
• Prone to data integrity issues
• Can only respond to an
issue/event days after
• Difficult to identify root
causes due to time lapse &
lack of understanding of
baseline
Environmental monitoring
Traditional plate techniques
Rapid techniques to read plates
Growth Direct
EviSight
Others?
Continuous viable
monitoring
BioTrak
BioLas
Others?
Water systems
At-line continuous monitoring
Sentinel MOBA
Mettler RMS7000
Biovigilance IMD-W
Traditional plate techniques
Rapid techniques to read plates
Rapid methods
Growth Direct
ChemScan RDI
MuScan
Milliflex Quantum
Others?
Support Monitoring – Environmental and Waters
IT Systems
To trend data
Support Monitoring – Steriliser/Decontamination
verification VHP verification
Traditional biological indicators
Standardization of approach to Bis
2018
Enzyme Indicators
Initial assessment complete
Extended validation/equivalency studies to performed
Routine use in cycles
VHP; Challenges of
Traditional Methods
• Live organisms taken into
controlled areas for
routine revalidation
• Yes/no answer
• Cycle design slow, as
need to wait for answers;
Leads to over-use of VHP
& extended aeration
cycles
• Long cycle times reduces
availability of isolators
• Limited knowledge of
cycle robustness
• Cannot use Bis to verify
every cycle
• Maintenance of BI &
verification time
consuming – prone to DI
risks
Example Implementation
The Challenges with Endotoxin Testing
Natural Assay = variable
2-20% invalid test rate
i.e. at some sites 20% of our tests are repeated due to invalid results, typically 8-12%
6 different iterations
used across AZ
Issues at one site could not easily be supported by
other sites
Different costs for
consumables & equipment
Even at country level
Cost dependent on 3 (main)
reagent suppliers
Time consuming
Lots of manual steps
Time to result – not an issue in small molecule world, but is an
issue at some of our biologics
sites.
Data integrity risks high
Manual prep
Manual Result interpretation
More parenterals
in our pipeline
Increased testing burden
One test may not suit all products
Capability gap
More parenterals globally increases
cost of goods
Reliance on a natural resource
Horseshoe Crab survival is out of
our hands
More parenterals globally
The Business Case for Charles River Endosafe®
• 12 sites doing endotoxin testing on water
• Spend >5000 hours testing these samples
• Use >17L HSC Lysate • >10% retest rate
• Switch water testing to Endosafe® • Testing time reduced <2000 hours • Lysate <1 L • Retest rate approx. 2%
Implementation Plan; • CRL Multi-cartridge system in use for >5 years at one site • Selected for new facility and currently under validation • Strategic implementation of Nexus robot for automation at higher volume sites • Target water testing to get technology in and “easy” regulatory path • Will transfer product over on a case by case basis, depending on the file • Implementation of instruments planned between 2018 and 2020
AstraZeneca Interaction with the MHRA Innovation Centre
• AstraZeneca visited the innovation centre to discuss with MHRA their advice and opinion on a proposed approach for an existing product sterility assurance continuous improvement program.
• AstraZeneca was in the early stages of planning additional improvements and investment in the manufacturing of this product relating to sterility assurance and wanted to seek input from MHRA on prioritisation of these improvement projects by using data from microbiology technical studies and risk assessments to focus improvements in highest risk areas.
• Two key areas AstraZeneca was interested in using as part of risk assessments included: Evaluation of heat treatment step in the process as a decontamination step. Assessment of the container closure integrity testing of a device which would not pass a typical container closure test.
Benefits of this Interaction
• MHRA gave advice on the microbiological aspects of the experimental design.
• Organism types • Expansion of the study to the whole process • Suggestions on how we might challenge the process with micro organisms • Suggestions on how to make the study robust to questions from regulators • Learning shared from other industry projects that had similar challenges and gave good
advice on non standard process. • When the agency then visited the site during inspection they were aware of both
studies, we shared results and progress. Advised on potential next steps to implement the findings of the studies and mitigate any risks.
24
• The agency have engaged in the facility and new line design and visited the wooden mock ups of the facility.
• Given advice on environmental
monitoring locations and risk assessment and area classification.
• Much smoother approval of the line
and a joined up approach to ensure the risks identified were assessed appropriately and mitigated with the correct containment and barriers appropriate for the product and patient.
• Facility recently inspected by MHRA.
Very smooth inspection.
MICROBIOLOGY MODERNISATION CROSS-INDUSTRY CONSORTIUM
Final comments
MMCC FUTURE PROJECTS • Hold regular technology update meetings
• Increase cross-company membership
• Expand expert network
• Engage with suppliers, academics & experts
• Regulatory advocacy – MHRA Innovation Office, EMA,
FDA Emerging Technology Team
• Sustainability initiative – Endotoxin testing
• Container Closure Integrity (CCI)
• Initiate revision of Pharm Europa chapter 5.1.6
MMCC COMPANY REPRESENTATIVES
• Miriam Guest AstraZeneca
• Karen Capper AstraZeneca
• Andrew Ray AstraZeneca
• Paul Newby GlaxoSmithKline
• Alice Laures GlaxoSmithKline
• Lisa Wysocki GlaxoSmithKline
• Sven Deutschmann Roche
• Wolfgang Eder, Roche
• Mousumi Paul Merck
• Philip Breugelmans JnJ
• Cedric Joossen JnJ
• Heike Merget-Millitzer JnJ
• Scott Weiss J&J
• Thierry Bonnevay Sanofi Pasteur
• Jeffrey Weiss Pfizer
INTERESTED?
• Karen Capper [email protected]
• Paul Newby, [email protected]
• Alice Laures, 2018 chair – [email protected]
• Miriam Guest [email protected]
MMCC Contacts in the UK