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    Sponsored by

    WWW.PHARMAMANUFACTURING.COM

    Holistic

    QbD

    Holistic Qb

    Developing a Qb

    Componen

    The Lifecycle

    Syringe Plung

    QbD for Pharm

    Packagin

    Componen

    Next Pag

    http://www.westpharma.com/http://www.pharmamanufacturing.com/http://www.westpharma.com/http://www.pharmamanufacturing.com/
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    Since FDA introduced the term to the pharma-

    ceutical industry in 2005, the concept o phar-

    maceutical Quality by Design (pharma QbD), a

    ramework or building quality into pharmaceu-

    ticals during drug development has been slowly

    gaining ground. Today, the leading name branddrug companies and a number o generic drug

    manuacturers are using Quality by Design meth-

    ods to optimize product development. Case

    studies have been published or solid dosage

    orms; biopharmaceuticals; and even, on a pre-

    liminary basis, or vaccines.

    The concepts behind QbD grew out o work

    published decades ago by such quality experts

    as Joseph Juran. They have been used in other

    industries or some time, but pharmaceutical

    manuacturers are now applying them to ensure

    consistent product quality despite variations in

    raw materials and other variables.

    Discrete industries are no strangers to QbD.

    Now, however, some vendors to the pharma-

    ceutical industries are applying pharma QbD

    principles to develop their pharmaceutical in-

    dustry products. This e-book oers general

    resources in the area o QbD, and discusses

    how West has been bringing a QbD approach

    to its packaging components. We hope that

    you ind it useul.

    2

    Contents3 Holistic QbD

    by Andy Polywacz, VP o QA,Americas, West Pharmaceutical

    Services

    6 Developing a QbDComponent:The Liecycle oSyringe Plungerby Tibor Hlobik, director, Global

    Prellable Syringe Platorm,West Pharmaceutical Services, Inc.

    9 QbD or PharmaPackagingComponentsby Paul Thomas, senior editor,

    Witt-Kieer

    13 Online Resources

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    Modern GMP expectations are transorm-

    ing the way drug products are being devel-

    oped, manuactured, evaluated and con-

    trolled. The movement rom ascertaining

    drug product quality predominantly by end

    product testing to achieving quality by de-

    sign (QbD) or eective and ecient manu-

    acturing processes is reinventing the GMP

    landscape. Harmonized guidances associ-

    ated with pharmaceutical development,quality risk management and pharmaceuti-

    cal quality systems (ICH Q8, 9 and 10) have

    initiated a ramework or science-based

    quality manuacturing.

    The goal during development is to have pre-

    dened objectives with emphasis on the

    product and understanding the manuac-

    turing process; controls are then based on

    knowledge to build the manuacturing sci-

    ence while employing quality risk manage-ment principles. Drug product ormulation

    development summaries should highlight

    the evolution rom initial concept to nal de-

    sign and take into consideration the choice o

    drug product container closure systems.1 An

    in-depth understanding o container closure

    components along with their manuacturing

    process will enable science-based decisions to

    support pharmaceutical manuacturing con-

    trol strategies. Aspects o container closure

    systems critical to drug product quality can

    be established during the drug development

    cycle by identiying potential attributes o the

    component and utilizing various risk

    management tools to evaluate risks.

    The level and ormality o risk as-

    sessments should be commensurate

    with the level o risk to drug product

    quality.2 It is possible to combine and coor-

    dinate process knowledge rom multiple unit

    operations to achieve a holistic picture o the

    entire drug manuacturing process, which can

    incorporate the science o component manu-

    acture. A mechanistic understanding o how

    drug ormulation and component manuac-

    turing process actors aect pharmaceutical

    quality will lead to:

    Eectieteclytatwillreduceset-

    backs when moving rom development to

    commercialization, realizing time and cost

    savings

    Data-driekwledetidetifycriti-

    cal quality attributes and establish control

    strategies

    H Qay by DegnBy Andy Polywacz, vice president, Quality Assurance,Americas, West Pharmaceutical Services, Inc.

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    Specicatisbasedwadwyte

    rubber ormulations, components and pro-

    cess actors impact drug product quality

    Beetstruuttelifecyclefa

    given product through trending o data or

    proactive management and eective con-

    tinuous improvements

    West NovaPure elastomeric components

    are ormulated and manuactured using

    a QbD approach that is holistic in nature.

    This approach takes into consideration

    the entire supply chain rom raw materials

    through distribution and drug packaging.

    Quality characteristics are engineered to

    meet the requirements o the pharmaceuti-

    cal manuacturer and help promote protec-

    tion/compatibility o drug product.

    The ollowing important QbD elements were

    used to develop and produce NovaPure

    components with a commitment toward en-

    hancing drug product quality:

    QualityTaretPrductPrle(QTPP)

    CriticalQualityAttribute(CQA)

    QualityRiskMaaemet(QRM)

    KwledeMaaemet(KM)

    CriticalPrcessParameter(CPP) CtrlStratey(CS)

    LifecycleMaaemet(LCM)

    CtiuusImpremet(CI)

    Consideration o all these actors during

    development o NovaPure components

    has achieved a well-understood compo-

    nent and robust processes that 1) deliver

    a component meeting the QTPP and 2)

    are controlled by dened steps within the

    manuacturing process. During commer-cial-scale manuacturing, the proactive

    trending o component perormance on

    a continuous basis provides a major ad-

    vantage through early detection o poten-

    tial issues and urther optimization o the

    control strategy to ensure reliable level o

    high-quality components.

    The holistic approach to the development

    o NovaPure components encompassed the

    actors associated with raw materials, as well

    as manuacturing process parameters re-

    lated to multiple acets o component qual-

    ity. A cross-unctional team o subject matter

    experts was employed to dene the scopeo the risk assessments and quality attributes

    to be evaluated. The risks were sorted and

    ranked based on the relative criticality o the

    various properties and attributes o the com-

    ponent. The analysis o unctional relation-

    ships distinguished the level o risk and pri-

    oritized relevant studies to evaluate risk.

    Manuacturing trials were conducted to as-

    sess quantitatively the relationship between

    process parameters and identiying CQAs.Desifexperimets(DE)quatitatiely

    predicted the eects o process parameters

    on quality attributes and multivariate analy-

    sis was employed to predict interaction o

    multiple process parameters, reducing un-

    certainty o areas having the greatest im-

    pact to component quality. Critical process

    parameters were identied through ull ac-

    torial analysis so that interactions o multiple

    process parameters were established within

    a given range or particular componentquality attributes. As multiple parameters

    were simultaneously examined to under-

    stand interactions between actors, an e-

    cient process to acquire and analyze data

    with higher precision or component qual-

    ity was achieved. The acquired data led to

    a well-understood component and revealed

    the sources o process and component vari-

    ability to be monitored and controlled. As

    holistic QbD practices were implemented

    or NovaPure components, upstream con-trols were put in place rather than quality

    by conormance related to capability o the

    process based on discrete actions.

    The demands o drug product regulation

    continue to evolve as a result o the increas-

    ingly global economy in which the supply

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    5

    chain has become central to assuring drug

    product quality. Qualication and procure-

    ment o raw materials or NovaPure com-

    ponents is initiated at concept develop-

    ment, employing risked-based assessment

    to achieve the desired component quality.

    Vendor quality and business practices areevaluated to ensure reliable supply o raw

    materials. These materials are proled to

    understand variability and enable control

    strategies. Monitoring raw materials used to

    manuacture NovaPure components secures

    the inventory through enhanced component

    and process understanding. Assurance o

    a reliable and readily available inventory is

    an important consideration or preservation

    o marketed drug product supply; a holistic

    QbD process or components contributesto this aspect. Additionally, other aspects o

    supply chain are considered relating to mini-

    mized, standardized lead time or commer-

    cial volumes, immediate shipment or small

    volumes and aspects o supply chain secu-

    rity built into the shipping cartons to rein-

    orce tamper evidence.

    The quality management system was tied

    into the data starting at development stages

    enabling science-based decisions to develop-ment o control strategies. Activities were o-

    cused on maintaining component quality as a

    result o knowledge gained to support CQAs

    and impact to the manuacturing process.

    Procedures were optimized or testing and

    analysis to develop specications to maintain

    a state o control and produce reliable com-

    ponent quality. Scientic data that supported

    control strategies are evaluated continually

    and include annual reviews, considerations o

    investigations and complaints to enhance un-derstanding o component and process.

    A distinguishing eature o NovaPure com-

    ponents is that attributes are assured

    based on identication and control o criti-

    cal process parameters (CPP) rather than a

    rigid, static manuacturing operation that is

    more susceptible to multiple manuactur-

    ing changes. Current regulatory expecta-

    tions are to have reduced uncertainty using

    data-supported evidence o suitable com-

    ponents during development through com-

    mercialization. The variability o NovaPure

    components has been minimized throughscientic-based assessments and is veried

    continuously with a course o action or con-

    tinuous improvement.

    Most importantly, the NovaPure brand pro-

    vides a shared quality commitment with

    pharmaceutical manuacturers, allowing

    greater predictability o component per-

    ormance, which can contribute to achiev-

    ing drug product with the quality attributes

    appropriate to meet the needs o patients,health care proessionals, regulatory au-

    thorities and internal customer require-

    ments. Transparency between pharmaceu-

    tical manuacturer and component supplier

    is realized through managing knowledge

    that is grounded in the nuances and com-

    plexities revealed through implementing

    holistic QbD. Included in this model is a

    24/7 customer support knowledge center

    to provide comprehensive inormation on

    the NovaPure product and QbD processes.The transition rom the GMP era o qual-

    ity management through checkbox compli-

    ance to science-driven assessment and jus-

    tications can be acilitated greatly through

    use o NovaPure components; a reliable

    supply o high-quality sterile components

    in a ready-to-use ormat.

    Reerene1 Guidance for Industry: Q8 (R2) Pharmaceu-

    tical Development Revision 2, US Depart-ment of Health and Human Services Food

    and Drug Administration, CDER/CBER, ICH

    November, 2009.2 Guidance for Industry: Q9 Risk Manage-

    ment, US Department of Health and Human

    Services Food and Drug Administration

    CDER/CBER, ICH June 2006.

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    6

    DEvELoPIngAQbDCoMPonEnT:

    the leye

    syrnge PngerBy Tibor Hlobik, director, Global Prellable Syringe Platorm,West Pharmaceutical Services, Inc.

    Market trends toward home-use and patient sel-administration o drugs

    used to treat chronic conditions (e.g., multiple sclerosis, rheumatoid ar-

    thritis and autoimmune) have made prellable syringe systems an ideal

    choice or single-dose drugs. Prelled syringe systems or vaccines,

    pharmaceuticals and biopharmaceuticals oer convenient, xed dosing

    and are adaptable to automated injection devices.

    For patients, use o a prelled syringe system has the potential to

    minimize microbial contamination and reduce medication dosing

    errors. The syringe systems oer ease o use and enhanced con-

    venience or those who require requent dosing, and when com-

    bined with an auto-injector system, can provide a more portable

    drug delivery system.

    Pharmaceutical and biopharmaceutical manuacturers who se-

    lect a prellable syringe system or their drug product may be

    able to reduce therapy and injection costs, as well as signi-

    cantly reduce overll when compared to single-dose vials.

    The system may also optimize the number o doses rom

    the existing drug supply, while oering a delivery option

    that will help to dierentiate the system in a crowded

    market and potentially increase patient preerence.

    Strategies employed in early phases o drug develop-

    ment that consider delivery devices such as prell-

    able syringes and their components can mitigate

    risk to quality, and position the product to meet

    needs o the ongoing drug product liecycle. The

    return on investment can be realized once a drug

    product is commercialized and has gained pa-

    tient loyalty through ease o use, therapeu-

    tic benet and high condence in the delivery

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    7

    device. While it is not easy to meet these

    challenges, a drug product manuacturer

    can benet rom early investment in the

    right drug delivery system and high-qual-

    ity components.

    Hgh-Qay cmpnen Faae

    Efen Manarng

    Most subcutaneous drug product injections

    utilize a staked needle 1mL long prelled

    syringe ormat that can retain a ll volume

    1.0mL. This syringe ormat is convenient,

    ts most auto-injectors and is widely usedor sensitive pharmaceutical and biotechnol-

    ogy drug applications.

    The use o high-quality components in pre-

    llable syringe systems will acilitate ecient

    manuacturing processes and support a reli-

    able supply o drug products. An elastomeric

    plunger is a critical element because it serves

    as the primary seal or container closure in-

    tegrity, maintains purity o drugs during shel

    lie, and unctions to expel contents o thebarrel and deliver drugs to the patient.

    Plungers (also named pistons and stoppers)

    are typically made rom butyl rubber and

    can be coated with a fuoropolymer lm,

    such as FluroTec lm, that can increase lu-

    bricity and serve as a barrier between the

    drug and the elastomer, reducing the poten-

    tial or extractables inherent in all materi-

    als. The phenomena o chemicals migrating

    rom the elastomers into the drug prod-uct is known as leachables, but the reverse

    process o the drug product adsorbing or

    absorbing onto the plunger can also occur.

    Extractablesadleacablescabesii-

    cantly reduced with a barrier lm.

    For improved manuacturing processes, the

    pharmaceutical industry has moved toward

    ready-to-use (RU) plungers or prellable

    syringe systems. These components are

    washed and sterilized prior to delivery to the

    drug manuacturer with specications or

    particulate and endotoxin, thereby reducing

    the risk o introducing microbiological con-

    tamination to the drug product during nal

    packaging. There are several methods orsterilization o plungers and an increase in

    extractable breakdown products have been

    observed under gamma radiation; thereore,

    autoclave steam sterilization o these com-

    ponents is a preerred choice.

    Qay by Degn: A New Way Mee

    inreang Regary and Qay

    Reqremen

    Quality by Design (QbD) promotes under-

    standing o the product and manuacturingprocess starting with product development.

    When designing and developing a product

    using QbD principles, manuacturers must

    dene desired product perormance and

    identiy Critical Quality Attributes (CQAs).

    The product and process is then designed

    to meet those product attributes, which

    leads to understanding the impact o ma-

    terial attributes and process parameters

    on the CQAs and identication and control

    o sources o variability. As a result o thisknowledge, a company can continually mon-

    itor and update its manuacturing process to

    assure consistent product quality.

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    Since prelled syringes are considered a

    combination product, which is dened

    by the agencies as A product comprised

    o any combination o a drug and device; a

    device and biological product; a biological

    product and a drug, or a drug, a device and

    biological product, two regulations apply:

    cgMPFiisedParmaceuticalspart21

    CFR 210-211

    QSRReulatifrDeices21CFR820

    Some o the primary areas covered by CFR

    820 and that dier rom CFR 210-211 in-

    clude management responsibility, purchas-

    ing controls, corrective and preventive

    action and design controls. As part o the

    industrialization o plungers using the QbD

    approach, aspects o CFR 820 must be in-

    corporated into the manuacturing process.

    Plungers that it 1mL long staked needle

    syringes were originally developed or a

    manual injection action. As customer de-

    mand or higher quality and patient need

    or sel-injection have evolved, demand

    or a high-quality plunger rose. Using QbD

    principles, West developed its NovaPure

    components or preillable syringe sys-

    tems to provide high reliability or break-

    loose and glide orce, dimensional consis-

    tency, sub-visible and visible particulate

    control, and low parts per million (ppm)

    deect attributes.

    The 1mL long NovaPure plunger ollowed

    a development liecycle program, which

    used a Quality Target Product Proile

    (QTPP) to establish CQAs or control o

    breakloose and glide orces. As the prod-

    uct which included risk-based design

    iputs,FiiteElemetAalysis(FEA)

    modeling, data generation on multiple

    concepts, and inal product perormance

    veriication with glass barrels rom mul-

    tiple suppliers o a 1mL long staked nee-

    dle syringe was developed, the QTPP

    served as a guideline to assure that tar-

    geted speciication values or breakloose

    and glide orce were met.

    Using QbD philosophy and principles can

    help to optimize breakloose and glide

    orces and signicantly reduce plunger

    variation rom part-to-part. Use o QbD

    principles ensures that components are

    developed based on science and data-

    driven decisions, as well as meet critical

    specication or deects, visible and sub-

    visible particulate and extractables con-

    sistently. In order to achieve a high-qual-

    ity product, QbD components are washed

    and steam sterilized or optimized material

    compatibility and the knowledge gained

    throughout the process used on an ongo-

    ing basis to maintain continuous improve-

    ment by the manuacturer. Selecting a

    manuacturing partner like West early in

    the development process can help phar-

    maceutical companies choose a high-qual-

    ity component or use in prellable syringe

    systems that will meet demands or high

    quality, improved total cost, and increased

    saety and security or the drug product.

    NovaPure and FluroTec are registered trade-

    marks of West Pharmaceutical Services, Inc.,

    in the United States and other jurisdictions.

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    At the PDA Annual Meeting

    in Phoenix in April 2012, West

    Pharmaceutical Services rein-

    troduced its NovaPure line o

    drug packaging components

    including serum and lyophili-

    zation stoppers and syringe

    plungers. What is unique

    about the new NovaPure is

    that, or the products design

    and development, West lever-

    aged the principles o Qual-

    ity by Design. West has long

    viewed itsel as a supporter

    o the industrys QbD eorts,

    but has now taken that sup-

    port one step urther. Its a

    vast change rom the way the

    company developed prod-

    ucts in the past, and may be

    seen as a sign that the infu-

    ence o Quality by Design is

    expanding beyond drug and

    device manuacturing and

    taking root in the vendor and

    solution provider community

    as well. (West has posted a

    video on YouTube with more

    details on how QbD played

    into the development o No-

    vaPure.)

    In anticipation o the Nova-

    Pure announcement, we spoke

    with Fran DeGrazio, Wests

    vice president or marketing

    and strategic business devel-

    opment. DeGrazio has nearly

    30 years o experience in the

    industry, is a requent speaker

    and author on pharmaceutical

    packaging and injectable drug

    products, and is a member o

    PDA, ACS and AAPS.

    9

    QbDFoRPhARMAPACKAgIngCoMPonEnTS:

    A sn Prvder Ge

    Mre sene-BaedBy Paul Thomas, senior editor, Witt-Kieer

    ViDEo NovaPure Components

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    http://www.youtube.com/watch?v=JOpnD2y_oJ4&feature=plcphttp://www.youtube.com/watch?v=JOpnD2y_oJ4&feature=plcphttp://www.youtube.com/watch?v=JOpnD2y_oJ4&feature=plcp
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    10

    PharmaQbD: How did the idea o apply-

    ing Quality by Design to the manuacture o

    components arise? What drove this initiative

    rom a business perspective?

    FlD: West initiated an intensive Voice o the

    Customer process several years ago to en-

    gage directly with key customers to identiy

    and assure that our direction and resource

    investments would correlate to the needs o

    our customers. As a result o that engage-

    ment, we provided guidance to R&D, Opera-

    tions and other unctions on customer ex-pectations. Although Quality by Design was

    never directly mentioned by a customer at

    that point, what was conveyed was the act

    that we needed a better understanding o

    our customers challenges and the perspec-

    tive o what they need to deal with rom a

    regulatory and end-user standpoint.

    As we do try to stay very close to the mar-

    ket and regulatory issues, we identied

    Quality by Design as a way to provide aproduct with improved understanding and

    less variability to our customers. We elt this

    was the ultimate eort to put ourselves in

    their shoes.

    PharmaQbD:Where did you begin the pro-

    cess? Who took the lead, and how challeng-

    ing were the training and other eorts to get

    buy-in rom all involved?

    FlD: The key to this program is that it ismulti-disciplinary i it is executed correctly.

    Initially this requirement was dened by our

    Marketing organization, but our R&D group

    quickly picked up the banner to help drive

    the program, along with our Operations and

    Quality organizations. It was exciting to see

    the understanding as people engaged ur-

    ther with the program and could see the re-

    sults and benets.

    The training or the organization has been

    intensive. O course, those directly in-

    volved with the development and manu-

    acture had more intensive training than

    those in the support areas. However, the

    entire organization has received training

    on Quality by Design rom the pharma-

    ceutical market perspective and how West

    has approached this initiative with our new

    West NovaPure brand.

    PharmaQbD: What was the biggest de-

    parture rom your previous manuacturing

    methods? In what ways were the old meth-

    ods non-QbD-like, i you will?

    FlD: The biggest change is a total reliance

    on data and science-based decisions versus

    a reliance on experience. At West we have

    many long-term employees who add value

    on a daily basis because o their experience.Our tendency in the past, however, was to

    rely too heavily on this aspect in both de-

    velopment and problem resolution. QbD is

    driven systematically through the genera-

    tion o data, so you are working based on

    acts and not assumptions.

    PharmaQbD:Lets take extractables and

    leachables as an example. How did you ad-

    dress them dierently in a QbD context?

    FlD: In respect o extractables, we have

    taken a multi-pronged approach: First, we

    have developed the VeriSure technical pack-

    age. This technical package provides in-

    depth extractables data to our customers

    and allows them to move into leachables

    testing more quickly.

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    11

    Second, using the VeriSure technical pack-

    age, we have conducted our own risk as-sessment o the identied extractables in

    order to study and evaluate anything that

    may be considered high risk.

    Third, as a part o the NovaPure product,

    we provide a lot-by-lot extractables nger-

    print. This is in addition to the QbD work.

    This provides condence to our customers

    that the extractables prole as indicated

    by our method is consistent over time.

    This minimizes risk or variation with drugproduct leachables.

    We realize that drugs take years to be de-

    veloped and approved rom a regulatory

    standpoint. They can then be on the market

    or years. This ngerprint approach helps

    provide an assurance o material consis-

    tency over those extended years.

    PharmaQbD:QbD requires coordination

    between those who research and develop aproduct and those will ultimately manuac-

    ture it. Can you share examples o how you

    have achieved better integration between

    key personnel throughout the development

    liecycle?

    FlD: Our R&D and Operations teams were

    engaged globally in this program. This was

    not a development and a hand-o but a co-

    operative eort o both parties. Additionally,

    we have instituted a global Knowledge Man-agement system to assure that inormation

    is stored and shared on an ongoing basis.

    PharmaQbD:What were the challenges in

    building a Quality Target Product Profle

    (QTPP)? What did your team learn rom the

    QTPP process?

    FlD: Marketing was responsible or den-

    ing the QTPP. However, the biggest chal-lenge was being able to provide the spe-

    cics and not assume anything. We ound

    the hardest part to be dening the Criti-

    cal Quality Attributes (CQA) with the R&D

    unction, as the CQAs needed to be mea-

    surable and specic.

    PharmaQbD: What are the critical qual-

    ity attributes (CQAs) or components such

    as stoppers and syringe plungers, and how

    were they determined?

    FlD: There may be multiple CQAs deined

    to achieve a target QTPP. We have these

    clearly deined, but the speciics are

    conidential and will only be shared spe-

    ciically with customers. The CQAs were

    determined through a combination o

    marketing, technical, R&D, laboratory and

    other experts working together, along

    with customer input.

    PharmaQbD:What key leanings rom the

    development o the NovaPure products will

    you incorporate into how you design and

    manuacture syringes and other products?

    FlD: We will continue to use these tech-

    niques or new products that are intended

    or customers and markets that will value

    this approach. A component built by Qual-

    ity by Design brings numerous benets to

    our customers. This involves things such asin-depth process and product understand-

    ing, a QTPP built around the patient and

    our customer, improved transparency due

    to a greater understanding and sharing o

    inormation and ultimately a lower total

    cost o ownership or the pharmaceutical

    or biopharmaceutical company.

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    The Advantage ofUnrivaled Quality...by Design

    Ensuring a drug product maintains its

    safety and efcacy from concept to

    commercialization while reducing total

    cost of ownership requires high-quality

    packaging components.

    West designed NovaPure components

    within a Quality by Design framework.Our data-driven process provides a

    deeper understanding of our product

    development and manufacturing

    processes. We apply this knowledge

    to components that can help customers

    build quality, safety and efcacy into

    their drugs.

    Our holistic approach encompasses

    a thorough process review, from raw

    materials to commercial manufacturing

    to transportation of components to the

    customers facility.

    NovaPure serum stoppers, lyophilization

    stoppers and syringe plungers areglobally available with a reduced lead

    time, and are provided in optimized

    packaging that helps ease the transition

    through manufacturing environments.

    West NovaPure

    #6669

    The New Definition of High-Quality Components

    West and the diamond logo and NovaPure are registered trademarks of West Pharmaceutical Services, Inc., in the United States and other jurisdictions.

    Copyright 2012 West Pharmaceutical Services, Inc.

    Unrivaled Qualityby Design

    To learn more about Wests

    NovaPure technology, call your West

    account manager or a Technical

    Customer Support representative.

    Contact West today.

    North America +1 800-345-9800

    Europe +49 2403 7960

    Asia Pacic +65 6860 5879

    www.westpharma.com

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    nne rerefor more informationclick on the links below

    cAN You sEEtHE REAl QbDGawayne Mahboubian-Jones

    http://www.pharmamanuacturing.

    com/articles/2011/068.html?page=ull

    iMPlEMENtiNGQbDby Helen Winkle, FDA

    http://www.da.gov/downloads/

    AboutFDA/CentersOfces/CDER/

    ucm103453.pd

    CLICKhERE

    CLICKhERE

    http://www.pharmamanufacturing.com/articles/2011/068.html?page=fullhttp://www.pharmamanufacturing.com/articles/2011/068.html?page=fullhttp://www.pharmamanufacturing.com/articles/2011/068.html?page=fullhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/ucm103453.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/ucm103453.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/ucm103453.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/ucm103453.pdfhttp://www.pharmamanufacturing.com/articles/2011/068.html?page=fullhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/ucm103453.pdfhttp://www.fda.gov/downloads/AboutFDA/CentersOffices/CDER/ucm103453.pdfhttp://www.pharmamanufacturing.com/articles/2011/068.html?page=full