ray scherzer fda acps october 26, 2005 breaking with tradition: the manufacturing challenges ahead!

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Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Page 1: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

Ray Scherzer

FDA ACPSOctober 26, 2005

Breaking with Tradition:

The Manufacturing Challenges Ahead!

Page 2: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Setting the stage

• The Traditional Pharma Business Model … changes underway

• Our current technology

• The challenge ahead!

• A vision of the future

• What can you do??

Page 3: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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The 70s, 80s and 90s … the traditional model

Double Digit G

rowth

+

+

Profits, $$$$$

Challenging Regulators

Page 4: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Industry pressures today

Pharma Industry

Regulatory Scrutiny

Attrition

Payer resistance

PoliticsPricing

Generics&Re-importation

Page 5: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Fundamental change in regulatory framework

Past

• Avoid change

• Quality “tested in”

• Regulatory fear

• Silo organisations

• Empirical science

Future Opportunities

• Innovation

• Good science

• Collaboration

• Efficiency

• Quality by design

• Real time release

Regula

tory

hurdle

sR

egulatory

hurdles

PATCGMPsCritical

path

Page 6: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Regulatory changes

• Major shift by FDA

• Dedicated Pharma inspectorate

• Approvals and inspections focused on scientific and engineering principles

• Hiring physicists, chem engineers, C&I engineers, statisticians ... Plus!

• Empirical methods are last resort

Page 7: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Significant impacts

• Higher scrutiny of existing products

• Higher expectations for new products

“If you can’t explain how your manufacturing processes work in the first 25 pages of your submission … the approval process will become much more difficult!”

Moheb Nasr, FDA, Director Office of New Drug Chemistry …

Page 8: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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The changing pharma business model

DiscoverDevelop

TestLaunch

Market

80s: 7 -8 yrs

90s: 8 -10 yrs

00s: 10+? yrs

$500m

$800m

$1,700m

Launch costsLaunch time Avg. ROI, %

9 -10

5

> 10

Page 9: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Today’s business is much different than yesterdays!

The Industry will and is changing!!

Page 10: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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CurrentTechnology

Page 11: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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DESCRIPTIVE KNOWLEDGE

CORRELATIVE KNOWLEDGE

CAUSAL KNOWLEDGE

MECHANISTICKNOWLEDGE

1st Principles

Control and release against process signature

Establish processEstablish processoutlineoutline

Prediction of performance (in-vivo)

Correlate process inputs and outputs

Relate critical process variables to quality attributes of finished product

2

1

3

5

4

Extent of knowledge

Manufacturing process knowledge

Industry

Page 12: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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V Blenders: lab and pilot plant scale

Page 13: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Commercial scale

Page 14: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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“We’ve got a few problems going from lab scale to full scale commercial”

Page 15: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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The Challenge Ahead!!

Page 16: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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DESCRIPTIVE KNOWLEDGE

CORRELATIVE KNOWLEDGE

CAUSAL KNOWLEDGE

MECHANISTICKNOWLEDGE

1st Principles

Control and release against process signature

Establish processEstablish processoutlineoutline

Prediction of performance (in-vivo)

Correlate process inputs and outputs

Relate critical process variables to quality attributes of finished product

2

1

3

5

4

Extent of knowledge

Manufacturing process knowledge

Industry target

Page 17: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Significant gaps exist:

• Manufacturing and scale up sciences

• Unit operation technology and control

• Academic training & skilled resources

• Industrial organization and structure

• Correlation to in vivo performance

Page 18: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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First steps: Unit operation science

• Reaction• Crystallization• Drying• Separation• Particle engineering

• Formulation• Dispensing• Blending• Granulation• Compression• Coating• Filling• Aseptic operations• Packaging

Material Handling, Analytical

Industry basic unit operations

Page 19: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Unit operations goals

• Well understood platform technologies• Develop the science of all unit operations• Fully instrumented• Closed loop control … fully automated• Material interactions (formulation & devices)• Predictable scale effects• Design/use the right equipment

• Predict performance without extensive experimentation

• Math modeling to speed design• GOAL: Final testing to confirm operations

Page 20: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Once UOs understood and platform technologies developed, then

Integrated Process Designs

Page 21: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Integrated process design: Objectives

• Aligns with FDA’s Quality by Design Concept• Link “Platform Technologies” in an integrated process

design• 1ST step of API to primary pack and device performance• Identify CCPs that affect up and down stream ops • Control systems will manage variability within the process• Link CCPs to traditional release testing; i.e. dissolution,

assay, CU, ACI• Produce in spec product by monitoring and controlling

critical parameters … rather than end point testing• Obtain real time release

Page 22: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

PROCESS FLOW DIAGRAM…….PANADOL CONTINUOUS PROCESS

BAG UNLOADING STATION

DISPENSING ROOM

IBC-01

IBC-01

HO-01A HO-01BHO-02

HO-05 HO-04 HO-03

IBC-02

F-01

F-02

F-04 F-03F-05

F-06

F-07

BL-03

BL-03

GR-01 GR-02

DR-01

M-01

BL-02

BL-01

SIFTED & PREWEIGHEDSTARCH MAIZEPOVIDONE

POT. SORBATE

PREGELATINIZED STARCH

CAFFEINE

PANADOL

GRANULATE

BASE

TABLET PRESS

SIFTED & PREWEIGHEDSTARCH MAIZESTEARIC ACIDMAG. STEARATETALCAVICILAC-DI-SOL

MOISTURE

PURIFIED WATER

METERING PUMP

1

2

6

7

7

89

33

5 5

4 4

2 2

TABLETS TO COATING

AHUAHU AHU

10

HO-03

SODIUM BICARB

PARACETAMOL

DELUMPER

FRESH AIR

PARACETAMOLPREGELATIZENED STARCHSODIUM BICARBONATECAFFEINE

IBC-01

IBC-02

SIFTER

SIFTER

SIFTER

SIFTER

SIFTER

DISPENSING ROOM

BL-03

11

DEDUSTER

METALDETECTOR

Integrated process design

Page 23: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Engineering models would:

• Process design tool of preference• Rapid evaluation of excipients, DS, formulations,

equipment, environmental, devices, etc.• Narrow alternatives in silica• Reduce scale up trial and error … focus testing on high

probability results … time & money!! • After confirmation, use model to demonstrate full

process understanding … regulatory expectation• Would be the basis for continuous improvement studies

Page 24: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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The future manufacturing vision!

• Fundamental understanding of the science• Develop mfg scale processes … before registration• Small scale, contained, dedicated, automated, continuous

processes • Late stage customization• On line measurement and control• Real time release • Product plants … not component plants• Leverage relationships … internal, academia, industry,

regulatory agencies to develop the science

Page 25: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Gaps in skills and facilities exist

• Manufacturing sciences

• Powder technology

• Chemical / Process engineers

• Rheologists (non Newtonian fluids)

• Physicists

• Spectromisists

• Chemometricians

• Process development pilot plants (not CT PPs)

• “Soft skills” & Business skills

Page 26: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Some current activities

• Industry/Company Culture changes underway• Empirical to fundamental sciences• Industry pressures key driver• External work lays foundation (FDA, ASTM, CAMP,

ISPE, IFPATma)

• Develop the next level of manufacturing science• PAT and cGMPs for 21st century• Pharma professional of the future … engineering +• Universities need to develop and teach the science

• Capitalize on today’s situation to forge an even stronger future

Page 27: Ray Scherzer FDA ACPS October 26, 2005 Breaking with Tradition: The Manufacturing Challenges Ahead!

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Your role in this:

• Support/create means for fundamental research in the Pharma manufacturing sciences

• Encourage students into science & engineering careers

• Encourage universities to create the programs• Be consistent and science based in your activities• Give this priority and attention

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Questions