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Professor Emeritus Senior Director, Director, Research
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from the editor
Regulatory Role
in Pharma Progress
Rita Peters
I
f you look back one year, the bio/ Regulations down, enforcement up issued by CDER in 2017 were nearly
pharma industry faced a number The report notes only six economically double the amount issued in 2014.
of questions. Drug approvals were significant regulations—all unrelated This jump in the number of warning
down. President Trump had issued an to pharmaceuticals or biotechnology— letters was triggered by increased en-
executive order calling for reducing the were released by FDA in 2017, compared forcement efforts authorized by the
number of regulations. And, the posi- with 30 or more in the previous four Drug Quality and Security Act of 2013
tion of FDA commissioner was vacant. years. This slowdown was the sole sig- and many targeted offshore API and
A recent report from PwC’s Health nificant “sudden change” observed by drug product manufacturing facilities.
Research Institute (1) summarizes the report authors. Rulemaking, how- Drug quality and data integrity were
long-term trends and changes in FDA ever, increased in the second years of the frequently listed violations. The
activities that occurred in 2017, and the Bush and Obama administrations; number of deficiencies found dur-
the implications for the bio/pharma the report notes that 18 pharmaceutical ing inspections held steady; failure
industry, and offers a performance regulations are under development and to have or follow written procedures,
evaluation for the agency and indus- could be published in 2018. failure to scientifically validate testing
try. According to the report, FDA had a procedures, and failure to fully inves-
good year in 2017; the agency approved
45 new molecular entities, the second
FDA’s strategy: tigate discrepancies in manufacturing
or testing processes were the most fre-
highest total in history, and the most Provide regulatory quent offenses.
generic drugs ever (763 full approvals
and 174 tentative approvals). These ap- relief and promote Regulatory relief
proval successes came as the number of Scott Gottlieb, who took over as FDA
new regulations declined but enforce- competition. commissioner in May 2017, has dem-
ment efforts increased. onstrated a strategy to “provide regula-
In addition, a record number of drugs While the number of rules decreased tory relief where appropriate, introduce
(476) received orphan drug designation in 2017, FDA continued to make policy competitive policies and eliminate re-
in 2017, an indication of the ongoing by issuing guidance documents with strictive ones, and promote innovation
trend of companies developing specialty user fees, generic drugs, and proce- and the exchange of information” (1).
and oncology drugs for smaller patient dural topics receiving the most atten- That approach should appeal to
populations. Under the 2017 tax legisla- tion. The 174 draft and final guidance pharmaceutical executives surveyed
tion, the tax credit for research and de- documents exceeded the average of by PwC; 36% of the respondents would
velopment costs for orphan drugs was 152 per year issued under the Obama like to see standards for approval, in-
cut in half, to 25%, lowering incentive Administration. Nearly 100 guidance cluding minimized regulations for
for companies to pursue such research. documents are on the Center for Drug lower-risk products, streamlined. Only
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Plant Personnel Training in all measuring points ranging from lab fermenters to
production processes and has measurement capabilities that
Honeywell’s cloud-based also include gaseous oxygen and temperature with accuracy
simulation tool uses a up to ±0.2%, in addition to temperature, partial pressure,
combination of augmented and raw measured values, according to the company.
reality (AR) and virtual The sensor is suitable for cleaning-in-place (CIP) and
reality (VR) to train plant sterilizing-in-place (SIP) procedures and works in process
personnel. The tool, temperatures from 15–280 °F and pressures ranging from
Honeywell Connected Plant 0–190 psi. The device also has a low sampling volume, making
Skills Insight Immersive it suitable for residual oxygen measurement in water treatment
Competency, can be used to bring new industrial workers up to and boiler feedwater. The sensor has a compact stainless
speed quickly by enhancing training in a contemporary way. steel 12mm design with lengths currently up to 220 mm.
The training solution combines mixed reality with data analytics The device connects to a transmitter via a cable that transmits
to create an interactive environment for on-the-job training. an optical digital signal, which is continuously monitored and
It uses Microsoft’s HoloLens, a self-contained holographic analyzed. The transmitter senses unusually high or low measured
computer, and Windows Mixed Reality headsets to simulate values, irregular values caused by incorrect measured values,
various scenarios for the company’s C300 controller—such and aging of the sensor cap. When errors are detected, the
as primary failure and switchovers, cable, and power supply transmitter displays a warning and produces an error message.
failure—that train and test personnel on their skills. Measured and calibration values in the sensor are sent to the
Specific job activities are simulated through virtual environments transmitter using a non-contact connection that has reduced potential
accessed through the cloud. According to the company, trainees interference, according to the company. Memosens technology in the
can safely experience the impacts of their decisions similar transmitter generates an automatic error message if the sensor fails,
to a flight simulator. This approach improves skill retention or if the connection between sensor and transmitter is interrupted.
versus traditional training methods by up to 100% and reduces Additionally, the sensor has integrated electronics that store
the length of technical training by up to 66%, as stated by the calibration data and other information, such as total hours of
company. Additionally, the employees’ training progress is operation and operating hours under extreme measuring conditions.
tracked as part of a formal competency management system. Calibration data are stored in the sensor, enabling the device to
be calibrated and adjusted independent of the measuring point.
Honeywell
www.honeywellprocess.com Endress+Hauser
www.us.endress.com
FDA Heightens
Drive for Transparency
Jill Wechsler
S
ecrecy and black-box operations access to confidential clinical research and Drug Administration (CFDA) is-
are out; public disclosure is the data and to limit publications to open sued draft guidance on policies for dis-
mantra for regulators and manu- access journals. Meanwhile, academic closing information regarding the ac-
facturers alike, as FDA explores more researchers have lagged in disclosing ceptance, review, and approval of drug
options for communicating agency clinical research activities, prompting applications. While aiming to keep
policies, approval decisions, and con- the National Institutes of Health (NIH) trade or technical data confidential,
cerns about product quality and safety. to threaten to cancel grants to organi- CFDA will make public information
The drive for greater transparency in zations that fail to meet requirements. on active ingredients, dosing, license
agency decision-making fits a range of holder, and patents 60 days following
health policy goals. More information A main demand— an approval.
on drug pricing, discounts, and rebates
is considered key to limiting payer from both Seeking CRLs
and patient outlays for prescription Despite expanded information dis-
drugs. The Federal Open Payments, consumer activists closure related to biomedical research,
or “Sunshine”, policy tracks industry drug marketing, and product safety,
payments, gifts, and transactions with and free market stakeholders want to know more
healthcare professionals to uncover any
industry influence on prescribers. And
deregulators— about the status of drug applications
and FDA’s decision-making process in
more timely and complete information
on product safety and recalls aims to
is for access to both rejecting and approving submis-
sions. A main demand—from both
prevent patient harm, as do efforts to complete response consumer activists and free market
make drug labeling more informative. deregulators—is for access to complete
A main transparency issue involves letters. response letters (CRLs) sent to manu-
public access to clinical study data and facturers that essentially delay or reject
results. While industry sponsors of Transparency also is considered im- an application and outline what addi-
clinical trials are meeting requirements portant for enhancing drug quality to tional clinical or manufacturing infor-
for listing new studies on the Clinical- reduce product recalls and shortages, mation is needed to achieve approval.
Trials.gov website, the record is weaker according to a white paper from the FDA currently posts summaries and
for timely posting of research results Office of Product Quality (OPQ) in reports on newly approved drugs and
for newly approved medical products. the Center for Drug Evaluation and biologics and has indicated interest in
The data transparency movement also Research (CDER) (1). As part of efforts also posting CRLs. But manufactur-
has prompted biopharma companies to to encourage manufacturers to adopt ers strongly oppose such a move as
provide scientists and researchers with continuous manufacturing and sys- CRLs usually contain trade secrets or
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Can Early
Development
Strategies
Avoid
Later-Stage
Disasters?
Rita Peters
A sssessin
ng pooteentiall formuu lation andd manuu factuu r ing issues inn
earrly deeveloopm
ment phasess can improove a d rug’s chan nces forr success.
hile some drug innovations are characteristics and the stability of the to clinic or get an investor or buyer in-
the result of surprises during drug substance during the toxicological terested in the potential drug. This ap-
research phases, a surprise that studies and planned clinical studies. The proach can be short-sighted, experts
occurs during development—such as application also requires information note, and drug companies would be
formulation or manufacturing prob- about inactive components planned for better served by focusing on getting
lems—could result in approval delays or the drug product and “any reasonable the drug to market. In presentations,
failure for a drug product. variations that may be expected during consultants and representatives of con-
To reduce the risk of late-phase sur- the investigational stage” (1). tract development and manufacturing
prises, some experts recommend that In the regulations, FDA notes that organizations (CDMOs) proposed that
additional screening efforts in early de- “modifications to the method of prepa- moving some formulation steps nor-
velopment can smooth the pathway in ration of the new drug substance and mally conducted in Phase I or Phase II
later development stages. Developers of dosage form and changes in the dosage to the preclinical stage can help identify
promising compounds emerging from form itself are likely as the investigation potential formulation and manufactur-
drug discovery must balance the need to progresses” (1). For a Phase I submis- ability roadblocks earlier in the develop-
better understand potential formulation sion, drug companies should focus on ment process and avoid later problems.
challenges and the manufacturability of the identification and control of raw
the drug product with the reality of time materials and the new drug substance, Building a better molecule
ARBALET/SHUTTERSTOCK.COM
and budget constraints. the Code specifies; the agency does not While speed is the top priority for most
For investigational new drug appli- expect final specifications for the drug small pharma companies with mol-
cations, drug owners are expected to substance and drug product until the ecules in discovery phases, drug can-
provide information about the phar- end of the investigational process. didate quality should be the top con-
macological and toxicological effects For drug development companies, sideration, said David Elder, principal
of a prospective drug product, as well particularly small startups, the focus consultant, David P. Elder Consultancy,
as its physical, chemical, or biological is often short-term: get the compound in a webcast (2).
18 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
If more work is done in medicinal Often, preclinical efforts are geared dle in the development process. Drugs
chemistry stages to optimize a molecule, to achieving a desired pharmacokinetic are frequently cited as fitting into one
formulation challenges may be easier to response in an animal model while mini- Biopharmaceutics Classification System
solve, said Elder. Historically, formula- mizing formulation development time (BCS) (4) classification; however, this
tion scientists were expected to “rescue” and cost. However, in vitro–in vivo rela-system is a regulatory tool to identify
molecules that were intrinsically insol- tionships are often not straightforward efficacy and patient safety, said Julien
uble. To get more drug candidates with and, therefore, require additional time Meissonnier, vice-president, science and
fewer solubility issues, drug companies and cost to establish, experts note. Phar-
technology, Catalent Pharma Solution, in
should focus more on the quality of the macokinetic studies using the API in a a webcast (2). A better tool for evaluating
candidate molecule—its lipophilicity, hydroxypropyl methylcellulose suspen- new drug development issues including
molecular weight, and ring systems— sion, may not give accurate results and permeability, solubility, dose, and disso-
and not just its potency. can result in formulation delays later inlution rate is the Developability Classifi-
Drug companies that fail to evaluate the development process (3). cation System (DCS) (5), he said.
the physicochemical characteristics and A range of in-silico modeling tools are Like the BCS, the DCS tool also catego-
manufacturability of a drug candidate in available to screen drug candidates to rizes molecules based on solubility, dose,
early development stages will not have predict degradation, metabolism, toxicity,
dissolution, and permeability. It further
adequate risk assessments of challenges solubility, and other characteristics, while
classifies Class II compounds, which
that may arise later in development conserving valuable API. Modeling also have low solubility and high permeabil-
stages, experts agree. Drug candidates is used to evaluate manufacturing ap- ity: Class IIa are dissolution-rate limited
with demonstrated data on solubil- proaches and excipient selection, and forand Class IIb are solubility-limited. The
ity, intestinal permeability, dissolution, scale up and design of experiments. dissolution of Class IIa molecules can
bioavailability, and dose will be more be enhanced by reducing particle size.
attractive to potential partnerships, ac- The solubility question Knowing where a drug candidate fits on
quisitions by other pharma companies, As drug molecules become more com- the classification scheme can expedite the
or financing from investors. plex, solubility has become a major hur- formulation process, Meissonnier said.
Booth 2833
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FDA: Early stage drug development costs trigger higher drug costs
In a series of speeches in the latter half of 2017, FDA Commissioner Scott Gottlieb “By front-loading the cost of drug discovery, the broader biomedical commu-
said that high costs and delays in early development efforts are setting the stage nity is making it harder to advance new ideas. It’s economically harder to capital-
for more expensive drugs—and drug program failures. The agency is introduc- ize the cost of an early-stage drug program, relative to funding a later-stage
ing initiatives to improve drug development efforts, but industry also needs to project. So, frontloading the costs are a recipe for reducing the amount of new
change preclinical, development, and clinical trial efforts. ideas that can be advanced,” he said (1).
While researchers have been able to use science to reduce the time from a Gottlieb outlined broad strokes for FDA initiatives that emphasize the mod-
breakthrough discovery to the creation of patient therapies, the process for de- ernization of the agency’s science, technology, and information foundations
veloping such opportunities is more costly, uncertain, and prolonged, especially to meet the demands of new therapies in development, including gene and
for new drug development, he said. cell therapies.
“We’re on an unsustainable path, where the cost of drug development is grow- “FDA’s goal is to make sure that our policies are as scientifically advanced as the
ing enormously, as well as the costs of the new medicines. We need to do some- products we’re being asked to evaluate. We need to make certain our principles for
thing now, to make the entire process less costly and more efficient. Otherwise, regulation allow and facilitate beneficial new innovation while making sure that
we won’t continue to realize the practical benefits of advances in science, in the FDA continues to meet its gold standard for safety and effectiveness,” he said (2).
form of new and better medicines,” he said (1). The Center for Drug Evaluation and Research is piloting the creation of a com-
The cost of a drug product is based on many factors, Gottlieb noted, including mon review memorandum to ensure early, cross-disciplinary interaction among
development expenses and the cost of the capital required to develop the drug; scientists and clinicians who have specialized knowledge in disease that informs
the greatest factor in the cost of capital is the risk of failure. product review.
To support an investment with a high risk of failure, investors expect a higher The agency is encouraging early engagement with product developers, espe-
potential return, which contributes to unaffordable drug products. If a drug de- cially small biotechnology companies who may not be familiar with the regulatory
velopment program will take a long time to get to market—and pay off—inves- filing process. Some sponsors sometimes overestimate the amount of information
tors will pursue alternative funding opportunities that offer faster returns and needed to file an investigational new drug application, front-loading the costs of
fewer risks. development, he explained. FDA’s review staff may be able to recommend steps to
Access to affordable drugs is a public health concern and FDA must “consider streamline the early development process by eliminating unnecessary preclinical
all of the factors that impact the cost of new products. That includes the cost of tests or by suggesting optimal pre-clinical or clinical designs, he said.
discovery and development,” said Gottlieb (1). “Ideally, it would be easier to get products into development, with more of the
The same policies that the agency pursued to advance the science of costs pushed further out, after some of the initial pre-clinical work is already
drug development and make that process more efficient must be di- done, and there’s a better understanding of whether a new product has clinical
rected toward lowering the cost of developing medicines, he said, and promise,” he said.
more focused clinical trials can help reduce overall development costs. References
However, he said, “on a relative basis, in many cases the cost of early 1. FDA, Dr. Gottlieb’s Speech to the Regulatory Affairs Professionals Soci-
ety (RAPS) 2017 Regulatory Conference, Sept. 11, 2017, Washington, DC.
stage drug development has grown at a proportionally faster rate than 2. FDA, Speech by Commissioner Gottlieb to Research America 2017 Na-
the cost of late-stage drug development” (1). tional Health Research Forum, Sept. 7, 2017, Washington DC.
References
1. 21 Code of Federal Regulations 312, Inves-
tigational New Drug Application.
2. Catalent Pharma Solution. “From Candi- Visit us at It’s not just about the products. It’s more
than just a clean surface. Contec prides
date to Clinic: Strategies to Select, Assess, Interphex New York itself on its longstanding technical
Formulate, and Deliver the Right Drug
Candidate in the Early Phase,” Webcast,
April 17 - 19 expertise, innovation and commitment to
quality. Continued improvements in lean
Oct. 10. 2017. Booth 1234 manufacturing, safety initiatives, vertical
3. A. Siew, Pharmaceutical Technology, 41 (10) global integration as well as Research
20–27 (2018). and Development, drive our critical
4. FDA, Waiver of In Vivo Bioavailability and environments product range forward.
Bioequivalence Studies for Immediate-Re- For more information, email
lease Solid Oral Dosage Forms Based on www.contecinc.com wipers@contecinc.com or call 864-503-8333.
a Biopharmaceutics Classification System,
T
he switch in emphasis in the phar- must deal with many different challenges in others new systems must be purchased.
maceutical industry from the de- simultaneously. “These molecules tend to Scale-up and optimization of small-
velopment of blockbuster drugs to by highly complex, and most have never volume processes can be challenging be-
therapies that treat rare diseases and been synthesized before except perhaps cause for many there is little information
smaller patient populations has led to at small scale in the laboratory. They also available in the literature. “It is essential
the need for small-volume current good typically require the application of spe- to consider all of the various process pa-
manufacturing practice (cGMP) API cific, sophisticated technologies, some rameters—temperature, pressure, mass
manufacturing capabilities. These APIs of which must be engineered for the first transfer, etc.—upfront,” Vispute observes.
must meet the same regulatory require- time,” says Ed Price, president and CEO Risk analyses for each unit operation—
ments as larger-volume drug substances, of PCI Synthesis. reaction and purification (extraction,
except at smaller scale and with less—but Practical syntheses must be devel- distillation, crystallization, filtration,
much higher value material—available oped that can be transferred to cGMP etc.), drying, and powder processing—
for analytical testing, and often under processes that consistently meet quality should be conducted to avoid problems
accelerated timelines. In addition, the requirements. Even though commercial at plant scale.
APIs used to formulate these products processes for these APIs involve smaller Joshua Hoerner, senior director of
are typically highly complex, requiring volumes than those of APIs intended for research and development at Noramco
multi-step syntheses using unusual re- blockbuster drugs, scale-up issues must Athens, notes, however, that solution
agents. Managing multiple projects can be still be addressed. Understanding critical mixing, pressure, and temperature
a challenge for contract development and process parameters (CPPs) and their im- challenges may actually be reduced on
SYDA PRODUCTIONS/SHUTTERSTOCK.COM
manufacturing organizations (CDMOs). pact on critical quality attributes (CQAs) a small-volume basis due to the smaller
CDMOs often manage at any one time is essential to understanding the process surface areas involved.
numerous small-volume API develop- and conducting risk evaluations for unit In some cases, the batch scale, which
ment projects involving a wide range operations and equipment to ensure is determined from the dosage strength
of chemicals targeting a broad array of “right-first-time” technology transfer, ac- of the final formulation, will impact the
therapeutic indications. As a result, they cording to Shyam Vispute, general man- choice of technology used in a synthesis.
ager of tech transfer at Neuland Labs. When developing peptides, for example,
Cynthia A. Challener is a contributing Analytical methods must also be de- researchers must determine whether
editor to Pharmaceutical Technology. veloped and validated, which can be solid-phase, solution-phase, or hybrid
22 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
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API Synthesis & Manufacturing
technology is most appropriate, accord- to implementing a small-volume cGMP probes for particle size distribution, par-
ing to Partha Pal, head of custom manu- synthesis to systematically identify and ticle vision and measurement (PVM)
facturing solutions and business develop- mitigate hazards that arise from innate probes for particle shape and polymorph
ment for Neuland Labs. chemicals or chemical reactions,” Ho- determination during crystallization pro-
Because most of these molecules have erner asserts. cesses, infrared (React IR , Mettler-Toledo)
not been synthesized on any appreciable for monitoring the real-time progress
scale before, it is also necessary to develop Maximizing process knowledge of reactions, and near infrared (NIR)
practical purification strategies, accord- One of the key technical and operational probes to perform drying profile studies
ing to Price. Poorly soluble compounds challenges associated with cGMP manu- for determination of desired polymorphic
falling in Biopharmaceutical Classifica- facturing of small volumes of intermedi- forms of temperature-sensitive products.
tion System (BCS) classes II and IV can ates and APIs is difficulty in obtaining The internal protocol at PCI Synthesis
be particularly challenging. “Exploring reliable reaction yields and consistent places emphasis on doing a good job at
all available techniques to improve solu- quality, according to Hoerner. Noramco building a practical process early on in a
bility and bioavailability, such as employ- tackles this issue with thorough process project. “Once the chemistry and analyt-
ing suitable techniques to modify the development efforts to maximize pro- ics are locked in, if any changes are needed,
physicochemical properties or increase cess knowledge and understanding. In- a tremendous amount of work will need
the specific surface area of the API pow- process controls for monitoring reaction to be repeated. That is why it is so impor-
der particles, is often necessary,” notes completion, crystallization, drying, and tant to take the time upfront to choose the
Girish Kavishwar, associate vice-presi- other critical steps are also used to en- right raw materials (considering cost and
dent of R&D at Neuland Labs. sure completion. availability), really understand the pro-
“Overall, we emphasize a company cul- cess, and build into the early stage chem-
Handle with care ture that focuses on the patient/customer istry what will be required down the road,”
Some isolated intermediates and APIs and ensures our products are of optimal Price observes. Process optimization
may be oily liquids, which can create han- quality and produced in a safe and com- using a DoE approach allows efficient yet
dling and stability challenges, according pliant manner,” Hoerner comments. thorough exploration of the design space.
to Hoerner. “Managing active ingredi- From a technical perspective, Noramco Method development for in-process and
ents that are predominately viscous oily begins at the R&D stage, selecting and final product testing and confirmation of
liquids is a significant challenge, both developing a phase-appropriate route process robustness and reliability at larger
from a handling and stability perspective. and evaluating critical raw material scale are then performed before moving
Noramco is working on dosage form so- sources, reagents/solvents, equipment, to GMP production.
lutions to help improve the processability and analytical controls to ensure robust
of such substances while also enhancing delivery of cGMP material. In addition, Solutions for complex problems
their commercial shelf-life,” he notes. Hoerner says that scale changes between Small-volume cGMP chemistry is clearly
Crystalline powders, on the other development and cGMP supply are mod- an area that can pose significant chal-
hand, may have different polymorphs eled with advanced software; process lenges. “The first focus should always be
and crystal habits that can impact drug analytical technology (PAT) or advanced on safety and compliance during manu-
product manufacturing robustness and offline analytical technologies are ap- facturing and ensuring robust produc-
the bioavailability of the API, Hoerner plied to synthetic steps that are highly tion of high-quality intermediates and
adds. “Identifying and stabilizing the complex or have significant risk to im- active ingredients,” Hoerner says. That
appropriate polymorph requires special pact product quality. cannot be achieved if small-volume API
skills and should be performed early on Neuland uses quality-by-design (QbD) manufacturing is treated as a commodity
in the process to avoid problems late in and design-of-experiment (DoE) ap- business, according to Price.
the development cycle,” agrees Pal. proaches beginning at the development “We work with many different small
Handling cytotoxic and highly potent stage to identify relevant process parame- companies, each with its own business
compounds is yet another issue. Appro- ters and identify the design space that will model, culture, internal resources, and
priate facility and equipment design is have minimal variations at the plant scale, level of experience. Each project they
required for handling such compounds, according to Vispute. Use of simulation bring us is unique, involving vastly differ-
and appropriate disposal facilities are software, such as for scale up and mixing ent raw materials, equipment, and chem-
also required based on their occupational behavior studies, allows the evaluation of istry. Flexibility and the ability to respond
exposure limits. Automation of process equipment performance prior to actual to the different needs of our customers
operations is also important for reduc- experimentation in the plant, leading to and their projects are crucial to success.
ing the exposure of operators and the reduced costs and development times for We must be able to bring a significant
environment to hazardous chemicals, ac- Neuland. PAT tools are used for real-time number of differing resources to bear to
cording to Pal. “A process hazard analysis measurement of CPPs, such as focused- create custom-tailored solutions to com-
(PHA) should always be conducted prior beam reflectance measurement (FBRM) plex problems,” Price concludes. PT
24 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
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Particle Engineering
cles onto the surface of the coarse par-
ticles and can produce particles with
designed functionalities, even with
highly sensitive APIs. These function-
alized particles enhance the inherent
properties of API without degrading
them in any way. There is no exposure
to heat/solvent, and the particles suffer
no attrition during processing, which
P
article surface modification is pressures, and/or solvents, making non-homogeneous mixes in an “in-
becoming a vital strategy in the these processes highly unsuitable for teractive mix” (3, 4, 6–9). Dry particle
pharmaceutical industry for “dif- unstable APIs that are degraded when coating overcomes the high cohesive
ficult to formulate” APIs. Most sur- exposed to such conditions. forces associated with the fine “guest”
face modification techniques, however, Aston Particle Technologies (APT) particles with the fines becoming
alter innate particle properties either has developed the world’s first aerosol- uniformly bound to surface of coarse
chemically or physically. These surface ized dry particle coating technology. “host” particles by strong forces of ad-
modification technologies involve the This technology is a one-step, ambient hesion. This principle holds true as
use of elevated temperatures, high temperature process, with controlled long as the size difference between the
processing parameters that can deliver guest and carrier particles is at least
Jasdip S. Koner is senior formulation repeatable product performance with double. Coating occurs because the
scientist; Eman Z. Dahmash is chief commercially available excipients. forces of attraction between fine and
scientific officer; David A. Wyatt is chief
The science underpinning this coarse are greater than the weight of
PIYAPHONG/SHUTTERSTOCK.COM
Table I: Common issues associated with the different commercialized dry particle coating techniques compared to Aston
Particle Technologies’ advantageous processing method.
Suitable for
No risk of No effect on
Technology name No heat generated No particle attrition pharmaceutical
contamination stability of API
applications
Mechanofusion
x x √ x x
(Hosokawa Micron, Japan)
Hybridizer
x x √ x x
(Nara Machinery, Japan)
MAIC
Magnetically assisted
x x x √ x
impaction coating
(Aveka, US)
APT
dry particle coating
√ √ √ √ √
technology
(APT, UK)
Figure 1. This schematic highlights the key steps in Aston Particle Technologies’ unique gram range. Through optimized process
dry coating process where the processes occur in parallel and allow the new composite development, a platform for the applica-
particles to be formed. Process parameters define the extent of coating and can be tion of the technology to a DPI formula-
controlled to produce powders with key quality attributes. tion has been registered as APT-Hale.
The controlled nature of the APT-
Hale process for DPIs leads to consis-
tent API delivery, which means that
the technology also determines the
dosing performance of the formulated
blend. The technology produces tight
Fine “guest” Coarse “host” Step 1 – Deagglomeration of Step 2 – Dispersion of fine Step 3 – Adherence of fine “guest” material on to
content uniformity and can also be
particles particles cohesive fine particles as well as any and coarse particles the surface of the “host” particles. Process
agglomerated coarse particles throughout blend conditions are controlled to drive complete
adsorption of guest on to carrier
tuned to deliver a particular fine par-
ticle fraction (FPF) as demonstrated
in Figure 3B, where a single-blend for-
mula processed in a designed set of
Figure 2. Scanning electron microscopy (SEM) and confocal microscopy images indicate experiments has been “dialled up” to
proof of concept of dry coating. A1 to A4 show deagglomeration of the fine particles deliver increasing FPF. The strength of
and adherence to the surface of the carrier. A1 and A2 show no fines in the field of view, adhesion between the fine and coarse
indicating they are all attached to the carrier. B1 to B4 highlight confocal results whereby particles can be controlled, thereby
a fluorescent guest has been coated on to non-fluorescent microcrystalline cellulose determining the amount of API that
(MCC); clear coating is observed on B1 and B3 with cross sectional images showing will detach from the carrier when
adsorption of the carrier to the surface of the MCC with the dark area highlighting the tested in the Next Generation Impac-
non-fluorescent core of the particle. tor. Because the blends carry little or
no electrostatic charge, they can be
handled immediately after processing
and require no conditioning or quar-
ALL FIGURES ARE COURTESY OF THE AUTHORS.
antine period.
To demonstrate the potential of the
technology in respiratory medicine de-
velopment and manufacture, a series
of designed experiments, using a QbD
approach, has been completed with
two different, commercially sourced
lactose carriers. The object of these ex-
periments was to optimize an API/lac-
tose formulation based on key critical
quality attributes. Optimizing time and
28 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
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• New thinking on sterile product manufacturing validation and process simulation
Register now to join the dialogue between manufacturers, suppliers, and regulators working
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A % Recovery % RSD B
8 APT-5 APT-6 APT-7 APT-8 APT-9 APT-10 APT-11 APT-12
100 120
6 100
80
% Recovery
Percentage/ μg
80
% RSD
60 4 60
40
40
2
20 20
0 0 0
0.5 0.75 2 5 10 Respirable material (μg) % Emitted % FPF Theoretical
Concentration (%w/w)
12
11 2. Q.T. Zhou et al., European Journal of
10 Pharmaceutical Sciences, 40 (5) 412-421
9 (2010).
8 3. T. Ishizaka et al., Chem Pharm Bull, 36
7 (7) 2562-9 (1988).
6 4. T. Ishizaka et al., J Pharm Pharmacol, 41
5 (6) 361-8 (1989).
1,000 1,200 1,400 1,600 1,800 1,000 1,200 1,400 1,600 1,800 2,000 5. L.E. Beach, Effect of Dry Particle Coating
Speed [rpm] Speed [rpm]
Sweet Spot Criterion met 1
on the Properties of Cohesive Pharma-
ceutical Powders, Dissertation, Otto H.
York Department of Chemical, Biological
and Pharmaceutical Engineering (New
Jersey Institute of Technology: New Jer-
sey, May 2011).
6. E.Z. Dahmash and A.R. Mohammed,
Expert Opinion Drug Delivery, 12 (12)
1867–1879 (2015).
7. J.A. Hersey, Powder Technology, 11 (1)
41-44 (1975).
8. C.W. Yip and J.A. Hersey, Powder Tech-
nology, 16 (2) 189-192 (1977).
9. H. Honda et al., Colloids and Surfaces A:
Physicochemical and Engineering Aspects,
82 (2) 117-128 (1994).
rotation speed of the blending process, Future work 10. R. Pfeffer et al., Powder Technology, 117
which were identified as critical process Although many of these experiments (1-2) 40-67 (2001).
parameters, demonstrated that the car- were carried out at laboratory scale, 11. V.A. Saharan and P.K. Choudhury, Acta
rier influences the processability of the APT recently collaborated with the Pharm, 61 (3) 323-34 (2011).
formulation (see Figure 4). The resultant automation engineering team at GB 12. L.J. Jallo et al., International Journal of
Pharmaceutics, 423 (2) 213-225 (2012).
design space enables the formulator to Innomech, which has designed and 13. USP 40-NF 35 (United States Pharma-
visualize a manufacturing control space developed a system to scale up the copoeial Convention, Rockville, MD,
for a formulation using either carrier. technology 100-fold. The system has 2017). PT
I
n recent years, many topical probiotic ucts are really worth the hype.” These teriophages were identified and isolated
personal care products have been scientific reviews are quick to point from the comedones and were then
launched into the market (1). In an out that well-crafted, vehicle-controlled propagated using an amplification pro-
August 2016 review for Dermatology clinical trial results are not generally cess and plated against different P. acnes
Times (2), dermatologist Patricia Farris available for topical semisolids contain- strains to determine breadth of efficacy
concluded, “The studies reviewed sug- ing live microorganisms. One reason to assure the selected phage was suitable
gest that topical prebiotics, probiotics, that topical probiotic therapies have to infect and eradicate pathogenic (in-
and bacterial cell lysates do provide not advanced beyond the personal care flammatory) P. acnes strains.
demonstrable skin benefits … At this “post-marketing surveillance regula- Formulating a living microorganism
time, it appears that more studies are tory environment” into the controlled is fundamentally different from formu-
warranted to determine if these prod- clinical trial “new drug approval regu- lating a small-molecule active topical
latory environment” is the difficulty product. Because the P. acnes probi-
in reconciling FDA microbiological otic or phage products will be dosed as
Jason Carbol is manager of Chemistry, requirements for a product containing suspensions, active solubility, solvent
Manufacturing, and Controls at Dow
MOTOROLKA/SHUTTERSTOCK.COM
Development Laboratories (DDL), a division live microorganisms. More specifically, compatibility, and penetration across
of Symbio, jcarbol@dowdevelopmentlabs. how can a topical suspension contain- the stratum corneum do not factor in
com; Pia Isabel Tan was a 2017 Dow ing more than 50,000 colony form- to the development of a topical probi-
Development Institute Intern who is currently a
biochemistry major at UCLA; ing units (CFU) of probiotic active otic. In contrast, the aqueous probiotic
Yug Varma, PhD, is CEO at Phi pharmaceutical ingredient (API) pass formulation does require that pH and
Therapeutics; and David W. Osborne, United States Pharmacopeia (USP) mi- osmolality be adjusted to values that as-
PhD, is executive fellow at Dow Development
Institute and senior vice-president of Product crobial enumeration testing (USP <61>) sure a favorable environment for the mi-
Development at Arcutis. (3), tests for specified organisms (USP croorganisms to remain viable. In these
32 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
two case studies, eight different formu- Figure 1: Deactivation of a probiotic Propionibacterium acnes (P. acnes)
lations containing preservatives were in aqueous product with hydroxyethyl cellulose (HEC) or Carbopol (Cp) in
tested for live microorganism viability preservative systems of methylparaben and propylparaben (Para), phenoxyethanol
over six weeks after compounding. (Phen), or potassium sorbate (Sorb).
Titer (CFU/mL)
Cp+Para
Therapeutics. Two gelled aqueous prod- 1.00E+05
HEC+Sorb
ucts were made with the intent of for- 1.00E+04
mulating cosmetically elegant products: HEC+Phen
1.00E+03
hydroxyethyl cellulose (HEC) at 1.5% HEC+Para
w/w and polyacrylic acid polymer or car- 1.00E+02
Results
When added individually to the probiotic formulations, the • nano-scale twin screw extruders
parabens, phenoxyethanol, and potassium sorbate com- • Production twin screw extrusion systems
pletely deactivated the product gelled with HEC or Car-
bopol by more than 99.95% within the first four weeks of • Pharmaceutical Extrusion Seminars
compounding (see Figure 1). • Process laboratory for melt/granulation extrusion
For the probiotic P. acnes strain, as shown in Figure 2, only
• Validation documentation and services
the 20% propylene glycol solution was reasonably tolerated.
The 20% propylene glycol solution initially lost 90% activity
at two weeks, but remained at a consistent level of activity
from two to six weeks. The 20% ethanol and the Carbopol Leistritz Extrusion
gelled water (non-preserved) products lost their potency by
FIGURES COURTESY OF THE AUTHORS
more than 99.95% within the first four weeks of compound- 175 Meister Avenue, Somerville, NJ 08876, USA
Ph 908-685-2333(PDLOVDOHV#OHLVWULW]H[WUXVLRQFRP
ing with the HEC gelled water (non-preserved) product per-
www.leistritz-extrusion.com
forming no better than 20% propylene glycol product.
The parabens, phenoxyethanol, and potassium sorbate
in isotonic HEC formulations did not deactivate the phage
six weeks after compounding. Formulating the phage with
ethanol or propylene glycol up to 20% solvent did not have
Melt extrusion + Granulation + Dosage Forms + Transdermals
any effect on phage activity (see Figure 3).
Pharmaceutical Technology MARCH 2018 33
Topical Drug Formulation
aerogenesis as determined by specified
Figure 2: Comparison of Propionibacterium acnes (P. acnes) in self-preserved
organisms of USP <62> is necessary for
solutions with ethanol (EtOH) or propylene glycol (PropGly) and non-preserved
the safety of any topically applied phar-
systems with hydroxyethyl cellulose (HEC) or Carbopol.
maceutical. It is passing antimicrobial
preservative effectiveness testing (USP
Probiotic P. acnes in Self-Preserving or Non-Preserved Systems <51>) that is the biggest hurdle to the de-
1.00E+08 velopment of a topical product contain-
EtOH
1.00E+07 ing a living microorganism as the active.
PropGly As seen for the probiotic P. acnes
1.00E+06
HEC strain used in the first case study, only
Titer (CFU/mL)
1.00E+05
Carbopol the addition of 20% propylene glycol
1.00E+04 was reasonably tolerated by the living
1.00E+03 microorganism active. The parabens,
phenoxyethanol, potassium sorbate,
1.00E+02
and ethanol, when added individually
1.00E+01 to the probiotic formulation, deacti-
1.00E+00 vated the product by more than 99.95%
0 1 2 3 4 5 6 7 within four weeks of compounding. The
Weeks 20% propylene glycol liquid initially lost
90% activity at two weeks, but remained
at a very consistent level of activity from
Figure 3: Bacteriophage in hydroxyethyl cellulose (HEC) with preservative systems two weeks through to six weeks. While
of methylparaben and propylparaben (Para), phenoxyethanol (Phen), or potassium a certain segment of the probiotic ac-
sorbate (Sorb) and with self-preserved solutions with ethanol (EtOH) or propylene tive appears susceptible to the cell mem-
glycol (PropGly). brane function interference exerted by
a glycol, sufficient quantities of viable
probiotic remain to manufacture an ef-
Bacteriophage in HEC and Self-Preserving Systems
ficacious topical product. Blending pro-
1.00E+09 HEC pylene glycol with other glycols to opti-
1.00E+08 HEC+Sorb mize antimicrobial activity has been an
1.00E+07 HEC+Phen area of active research within the field
1.00E+06 of dentistry (7). The results of the first
Titer (PFU/mL)
HEC+Para
1.00E+05 case study, combined with the literature
EtOH
1.00E+04 concerning the bactericidal activity of
PropGly
1.00E+03 propylene glycol, indicate that addi-
1.00E+02 tion of glycols to a fluid suspension of
1.00E+01 probiotic P. acnes is a reasonable devel-
1.00E+00 opment strategy for complying with 21
0 1 2 3 4 5 6 7 CFR 211.113(a).
Weeks As expected, the phage was more
resilient to the addition of preserva-
tives to the formulation. Addition of
compounding and caused more than objectionable microorganisms in drug ethanol to the formulation did not ap-
99.95% loss in phage titer by four weeks.products not required to be sterile, shall pear to have any effect on the phage.
be established and followed” (6). It The parabens, phenoxyethanol, potas-
Discussion should be noted that a topical probiotic sium sorbate, and propylene glycol did
The basis for microbial enumeration product should not have greater diffi- not appear to deactivate the phage six
testing (USP <61>), tests for specified culty in passing USP <61> or USP <62> weeks after compounding. The use of
organisms (USP <62>) and antimicro- than topical products containing non- a negatively charged polymeric gell-
bial preservative effectiveness (USP living actives. For topical probiotics, the ing agent did deactivate the phage by
<51>) of topically applied non-sterile living microorganism active is not “ob- approximately 95% two weeks after
pharmaceutical products is the state- jectionable” and thus is not required by compounding and caused more than
ment in US 21 Code of Federal Regula- USP <61> to be below 1000 CFU. Like- 99.95% loss in phage titer by four weeks.
tions (CFR) 211.113(a) that “Appropriate wise, the absence of pathogens such as Obtaining a preserved bacteriophage
written procedures, designed to prevent Staphylococcus aureus or Pseudomonas probiotic topical gel is possible pro-
34 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
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Topical Drug Formulation
have been relatively stable from weeks
Figure 4: Bacteriophage in Carbopol (Cp) with preservative systems of
2–6, indicating that this is a reasonable
methylparaben and propylparaben (Para), phenoxyethanol (Phen), or potassium
development strategy. From the results
sorbate (Sorb).
obtained from these two case studies, it
can be concluded that it is possible to
Bacteriophage in Carbopol Systems formulate a preserved topical product
1.00E+09
containing living microorganisms.
Carbopol
1.00E+08
Cp+Sorb References
1.00E+07
Titer (PFU/mL)
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According to the modern requirements of the ormative requirements for finished medicine produc-
European Union’s Good Manufacturing Practice for tion are constantly being improved. These changes
Medicinal Products, a manufacturing authorization are associated with progress in science and technol-
ogy, improvement of control methods and engineer-
holder should guarantee the suitability of
ing support systems for manufacturing, development and
excipients included in the finished medicine. launch of next-generation drugs to the market, enhance-
For this purpose, a formalized, documented ment of the control systems for technological process and
assessment of risks associated with safety, quality, products, and the introduction of new pharmacopoeial and
and function for each excipient should be carried regulatory requirements, for example. The European Union
out. Though the EU-GMP guidelines give an good manufacturing practice (EU-GMP) requirements (1)
are meant to be mandatory rules in the field of pharmaceuti-
indicative list of parameters that should be taken
cal production, and the EU-GMP rules are amended almost
into consideration when assessing the excipient every year. These changes encompass both the structure
risks, none of the known and cited sources specifies and the content of the document, including modification of
how to perform such an assessment. The present the conceptual framework for GMP. The most recent GMP
article, therefore, describes a new, combined, changes were comprehensive (2).
quantitative method for assessing excipient risks In the new requirements of the EU-GMP Chapter 5, it
is noted that the level of supervision over starting material
that has been developed by the authors as one
manufacturers should be proportionate to the risks associ-
possible risk evaluation method. This method ated with particular types of starting materials, taking into
represents a combination of a quantitative risk account the source, production technology, supply chain,
assessment (based on the risk index method) and its use in the composition of a finished medicine (1).
and a qualitative risk ranking method. The risk The new regulation is focused on assuring the quality of the
components related to safety, quality, and function excipients that influence the quality of the finished phar-
maceuticals. Finished medicine manufacturers, therefore,
of excipients as well as parameters included in
should monitor manufacturers and suppliers of excipients.
them are considered, and the score points are For this purpose, it is necessary to use an approach based on
assigned to each excipient. The developed method a documented risk assessment, which is described in the new
was used for excipient risk assessment of some guidelines, adopted in 2015 (3) and entered into force in the
marketed finished medicines manufactured EU since March 21, 2016. In turn, these guidelines (3) have
MONA MAKELA/SHUTTERSTOCK.COM
by Ukrainian pharmaceutical enterprises. been developed and adopted in pursuance of the Directive of
the European Parliament and the EU Council 2011/62/EU (4),
which has made appropriate changes in the Directive 2003/81
(the primary regulation for the drug distribution chain) (5).
According to the normative documents (3–5), the manu-
facturing authorization holder (MAH) should guarantee the
suitability of excipients used in finished medicine manufac-
Submitted: Nov. 21, 2017 ture by determining an appropriate set of GMP requirements.
Accepted: Jan. 4, 2018 In turn, this set should be determined on the basis of a for-
38 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
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Peer-Reviewed
Table I: Instructions for assigning parameters and score points to the Safety (S) malized overall assessment of excipient
excipient risk component. risks. The task to guarantee the quality
of the excipients is quite complicated
Safety (S) Score
because the manufacturers of excipients
Spongiform encephalopathy: S1
mostly aren’t MAHs and are not covered
Raw materials of animal origin are used for the manufacture of excipient 1 by regulatory GMP-inspections. More-
Raw materials of animal origin are not used for the manufacture of excipient 3 over, such manufacturers may refuse to
Potential for viral contamination: S2 be audited by MAHs. Thus, one way a
Impossible 1 MAH can determine if an excipient is
Possible but not significant for this particular pharmaceutical form 2 of appropriate quality and can be used
Possible and significant for this particular pharmaceutical form 3
safely in finished drug manufacturing
is by doing a risk assessment.
Potential for microbiological or endotoxin/pyrogen contamination: S3
An overall risk assessment should
Excipient has a synthetic origin and is resistant to microbial contamination 1
take into account the requirements of
It is possible, but not significant for this particular pharmaceutical form 2 other relevant quality systems to deter-
It is possible and significant for this particular pharmaceutical form, 3 mine the origin and the intended use
in instance, raw materials of animal and/or vegetable origin are used
of the excipients, as well as previously
in the excipient manufacturing process or the excipient could serve
as a substrate and stimulate the growth of micro-organisms recorded cases of defects in their qual-
Potential for any impurity originating from the raw materials (e.g., aflatoxins or
ity. A system of an overall assessment
S4 and management of excipient risks is
pesticides):
Raw materials of vegetable origin are not used in the excipient manufacturing process 1
incorporated in the pharmaceutical
quality system of a finished medicine
Raw materials of vegetable origin are used in the excipient manufacturing process 3
manufacturer. All actions within ex-
Potential for any impurity generated as part of the process and carried over (e.g.,
S5 cipient risk assessments are docu-
residual solvents and catalysts):
mented and are subject to GMP inspec-
Low potential for such an impurity 1
tion. A risk management approach has
High potential for such an impurity 3
been implemented in pharmaceutical
Sterility assurance for excipients claimed to be sterile: S6 manufacturing for more than 10 years,
The excipient sterility is ensured 1 and methods and tools that can be
There are some problems with the excipient sterility ensuring 2 used in the risk management prosess
The excipient sterility is not ensured 3 are described in International Council
Potential for any impurities carried over from other processes, in absence of for Harmonization (ICH) Q9 (6). This
S7 list, however, is not exhaustive and
dedicated equipment and/or facilities:
Low potential for such impurities 1 could be expanded using other tools or
High potential for such impurities 3
combinations. Numerous examples of
risk assessment methods and tools are
described (7, 8), but information about
Figure 1: Low-, medium-, and high-risk areas (respectively, which approach is useful for excipient risk evaluation and
from left to right) derived from the risk components: safety (S), details of how this evaluation could be done are lacking.
quality (Q) and excipient function (F), expressed in score points This article, therefore, aims to provide such information.
from one to three. The guidelines (3) establish the fundamental principles
that should guide a finished medicine manufacturer in the
excipient risk assessment and note that the instruments
and methods described in ICH Q9 (6) can be used for this
purpose. The guidelines (3) provide an indicative list of
parameters that should be taken into consideration when
FIGURE IS COURTESY OF THE AUTHORS
Solutions
areas in the resulting three-di-
mensional space were determined.
• From the three-dimensional space
in the risk assessment, one can
move to a simpler and more un-
derstandable qualitative rank (low,
medium, or high risk).
• The developed method is tested
by assessing risk of commercial
excipients from Ukrainian phar-
maceutical enterprises.
E-
Ve
D
ca L y
S
nM HV riP ca
ic r o C u r re n t a c Va c u u m D e
The guideline (3) identifies quality (Q),
safety (S), and function (F) of excipients
in a finished medicine as the components
that affect excipient risk. Each of the risk PTI - Packaging Technologies and Inspection
914.337.2005 | www.ptiusa.com | Tuckahoe, New York
components for an individual excipient
is represented in the form of coordinate
Pharmaceutical Technology MARCH 2018 41
Peer-Reviewed
Table II: Instructions for assigning parameters and score points to the Quality With a chosen scale of one to three
(Q) excipient risk component. Parameters not included in guidelines (3) are in score points for each risk factor, the
italics. maximum total risk index will be equal
to 27, using Equation 1:
Quality (Q) Score
Control of transportation and storage conditions, including cold chain management: Q1
TRI = S × Q × F = 3 × 3 × 3 = 27
No cases of non-observance of established conditions 1
for transportation and storage upon delivery
The minimum possible risk will be
Only one case of non-observance of the conditions for 2
one, using Equation 1:
transportation and storage as delivered
More than one case of non-observance of conditions for 3
transportation and storage upon delivery
TRI = S × Q × F = 1 × 1 × 1 = 1
Supply chain complexity: Q2
Within the framework of this ap-
Direct supply chain from excipient manufacturer 1
proach, the risk indexes of each excipi-
Supply through one distributor 2 ent in each finished medicine are cat-
Supply through two or more intermediaries 3 egorized by Equations 2–4:
Stability of the excipient: Q3
No problems with stability of the excipient 1 Low risk: 1 ≤ TRI < 6 [Eq. 2]
Problems with stability of the excipient 3
Assurance of package integrity: Q4
Medium risk: 6 ≤ TRI <12 [Eq. 3]
No package defects or integrity failure have been identified 1
High risk: 12 ≤ TRI ≤ 27 [Eq. 4].
A few single cases of package defects have been identified 2
Multiple cases of significant package defects have been identified 3 Additional requirements may be used
Related to the excipient quality defects or adulterations, identified both globally and when assigning a category. For example,
Q5
at a local company level:* if the value of at least one of the com-
No defects and adulterations have been identified 1 ponents (S, Q, or F) is three, then the
Single defects have been identified 2 overall risk in any case cannot be attrib-
Adulterations have been identified 3 uted to a low risk area, but should be at-
Results of sterility input control for the excipient claimed to be sterile: Q6 tributed to the medium or high risk. It
At least one recorded case of a nonconformance of the excipient in this parameter 3
should also be understood that although
Figure 1 gives an idea of the risk areas in
Any excipient defects recorded during reported period, which were identified in the
Q7 the chosen three-dimensional space, it
input control:
A proportion of identified defects less than 1% 1
is rather simplistic, because in practice,
calculated values of risk components
A proportion of identified defects from 1% to 10% 2
will not be round numbers, but non-
A proportion of identified defects more than 10% 3
integral values, as described previously.
Results of input control for the critical quality attributes of the excipient (e.g., Defining component parameters.
Q8
identification, pyrogenicity, toxicity):
An important aspect of risk assessment
At least one recorded case of a nonconformance of the excipient 3 within the framework of this algorithm
Results of input control for significant quality attributes of the excipient (e.g., assay
Q9 is identifying the parameters that are in-
content, impurity content, microbiological purity): cluded in each of the risk components.
At least one recorded case of a nonconformance of the excipient in this parameter 3 Certainly, the choice of the main param-
*This parameter was included in F in the guidelines, but here is included in Q. eters should be guided by the norma-
tive document (3), but it insufficiently
S, Q, or F as the arithmetic mean of the parameters included defines which parameters are included
in each of the components. To decrease the error of the over- in each of the components. In addition, the normative docu-
all risk assessment, when calculating the arithmetic mean of ment does not contain a clear separation of the parameters
the parameters at the stage of component assessment, one included in the individual components of excipient risk. In
should not round the obtained values to whole numbers. the authors’ opinion, for some components, the listed param-
Rounding should be limited to the first significant digit eters should relate to another risk component. For example,
after the decimal point. By substituting such values into the following parameters are assigned to the functional char-
the formula (1), a more accurate assessment of the overall acteristic of excipients in the finished medicine (3):
risk index is obtained, and the resulting value is rounded • The pharmaceutical form and use of the finished medi-
to whole-number values at the final stage of the calculation. cine containing the excipient
42 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
• The excipient function in the fin- Table III: Instructions for assigning parameters and score points to the
ished medicine (examples are given) excipient function (F) risk component. Parameters not included in guidelines
• The proportion of the excipient in (3) are in italics.
the finished medicine composition
Excipient function (F) Score
• Daily patient intake of the excipient
Pharmaceutical form and use of the finished medicine containing the excipient: F1
• Any known excipient quality de-
fects/adulterations, both globally External (topical) administration 1
associated with defects of excipient Three or more functionality-related characteristics described in the 3
quality or adulterations refers not to Ph.Eur. monograph are related to this particular excipient function
a functional characteristic, but to the The proportion of the excipient in the finished medicine composition: F3
quality risk component (Q). Moreover, Proportion of the excipient does not exceed 10% 1
the parameters referred to the safety Proportion of the excipient is between 10% and 40% 2
and quality risk components in the Proportion of the excipient exceeds 40% 3
guidelines (3) are not separated and are Daily intake of the excipient administered with the finished medicine to a patient F4
given in one list. Understanding how
Up to 100 mg 1
these parameters relate to precisely
From 100 mg to 500 mg 2
those risk components is unclear, and
additional information is needed. To More than 500 mg 3
better define the F component, the au- Whether the excipient is a mixture: F5
thors used the approach of the European The excipient is not a mixture, but an individual substance 1
Pharmacopoeia (Ph.Eur.) Chapter 5.15 The excipient is a premixed blend of two individual substances 2
“Functionality-related characteristics of The excipient is a premixed blend of more than two substances 3
excipients” (11). Although this chapter The impact of the excipient (its function) on providing established biomedical
is not mandatory, it is useful in the au- F6
requirements to the finished medicine:
thors’ excipient risk assessment method. The excipient does not affect biomedical requirements 1
The authors also added several param-
The excipient function is directly linked to providing 3
eters to the Q component. biomedical requirements to the finished medicine
The final step in developing risk as- Known or potential impact of the excipient on the critical quality attributes of the
sessment algorithm was to determine F7
finished medicine:
what points (and in what cases) should The finished medicine meets specification criteria even when a 1
be assigned to each of the parameters proportion of the excipient is changed by ±50% of the nominal
included in each risk component. Tables The finished medicine meets specification criteria when a proportion of 2
I–III list the instructions and the point the excipient is changed by not more than ±25% of the nominal
values developed by the authors. The finished medicine meets specification criteria when a proportion of 3
the excipient is changed by not more than ±10% of the nominal
Table IV: The results of the risk assessment for the excipients included in the medicinal product “Insular Stabil”.
Excipients, included in the medicinal product Risk components Total risk index
No
composition S Q F (TRI)
1 Protamine sulfate 1.7 1.9 2.1 7
2 Di-Sodium hydrogen phosphate dehydrate 1.4 1.6 2.0 4
3 Glycerol 1.6 1.7 2.0 5
4 Meta-cresol 1.3 2.0 2.0 5
5 Phenol 1.3 1.6 2.0 4
6 Water for injections 1.4 1.3 2.1 4
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BROUGHT
TO YOU BY
Quality
The guidance document emphasizes
the need for good communication be-
tween owners and contract facilities. It
also emphasizes the shared nature of
the responsibility to comply with CGMP.
Neither party can blame the other for its
failure to meet CGMP.
F
DA finalized its guidance on con- swer is mixed; yes, many are, but there is activities such as processing, packing,
tract manufacturing, Contract Manu- room for improvement. In this article, the holding, labeling operations, testing, and
facturing Arrangements for Drugs: authors cover the scope and legal under- quality unit operations.
Quality Agreements, in November 2016 pinnings of the guidance, as well as what Owners and contract facilities interact
(1). This document explains how parties FDA investigators may consider regarding in a variety of ways. An owner could be a
that engaged in contract manufacturing a quality agreement during an inspection. product sponsor or an entity that decides
can use quality agreements to delineate The article also provides some examples to make and market products. An owner
their roles and ultimately ensure compli- of issues related to quality agreements that could contract out all the manufactur-
ance with current good manufacturing FDA has called out in warning letters since ing activities, but when an owner uses
practice (CGMP). the guidance was finalized. a contract facility, the owner’s quality
In the months since FDA finalized this In talking about the parties involved in unit remains responsible under CGMP
guidance, how has industry responded? contract manufacturing of drugs, the term for approving or rejecting drug products
Are manufacturers that establish contracts “owner” is used to mean manufacturers of manufactured by the contract facility, in-
for specific manufacturing activities using APIs, drug substances, in-process materi- cluding for final release.
quality agreements effectively? The an- als, and finished drug products, including There are numerous reasons for owners
DOCSTOCKMEDIA/SHUTTERSTOCK.COM
Legal background
Drugs not manufactured in conformance with CGMP are deemed
adulterated under Section 501(a)(2)(B) of the Federal Food, Drug,
and Cosmetic Act (FD&C Act). Under this statute, a drug is adul-
terated “if the methods used in, or facilities or controls used for,
THE BEST DESERVES THE BEST
manufacturing, processing, packing, or holding do not conform
Since 1992, Marchesini Group USA
with CGMP.” Manufacture, processing, packing, or holding of a
drug product is defined as “includ[ing] packaging and labeling
has been one of the leading companies
operations, testing, and quality control of drug products” (2). supplying the most technologically
In 2012, the Food and Drug Administration Safety and In- advanced packaging solutions
novation Act (FDASIA) amended Section 501 of the FD&C Act, to the North American pharmaceutical
clarifying that CGMP “includes the implementation of over- and cosmetic industries.
sight and controls over the manufacture of drugs to ensure qual- MARCHESINI GROUP USA: info@marchesiniusa.com
ity, including managing the risk of and establishing the safety PROVIDING THE BEST SINCE 1992. WWW.MARCHESINI.COM
of raw materials, materials used in the manufacturing of drugs,
and finished drug products.” This amendment clarified the
link between a firm’s quality management activities and CGMP. BOOTH 3125
CGMP regulations require that the quality unit’s procedures Jacob Javits Center, NY | April 17-19, 2018
and responsibilities are in writing, and that they are followed (3).
Pharmaceutical Technology MARCH 2018 49
Quality
only mechanism for ensuring that owners • Firms attempted to contract away re- our customers conduct testing to confirm
and contract facilities comply with CGMP. sponsibility. stability and expiration dating.” The firm
What is important is that the respective Many of these examples also illustrate also responded that it was contacting its
parties’ quality unit responsibilities and how poor practices can put patients at customers to confirm responsibilities and
procedures are in writing and are followed. risk due to the failure of the parties to en- OTC drug product expiration dating. FDA
As noted earlier, FDA regards contract sure product safety and quality. In some put the company on import alert and sent a
facilities as extensions of the drug owner. of these cases, FDA sent warning letters warning letter with a courtesy copy to the
Owners’ quality units retain legal respon- to the contract facility with a courtesy owner. In this example, the contract facil-
sibility for approving or rejecting drugs copy to the owner. In other cases, both ity made a bad assumption. This illustrates
manufactured by the contract facilities, the owner and the contract facility re- why all parties must be aware of their roles
including final release of drugs. That is to ceived warning letters. and responsibilities to ensure adulterated
say, CGMP responsibilities cannot be con- product is not marketed.
tracted away with quality agreements. As When the owner falls short In another example, FDA cited a con-
FDA has made clear in numerous warn- In a recent case, FDA investigators found tract facility making OTC drugs with nu-
ing letters, owners are responsible for the that a drug manufacturer failed to vali- merous violations the same as or similar to
quality of drugs they produce, regardless date its manufacturing processes and to those in past inspections, such as failure to
of the agreements in place with contract test components used in drug manufac- validate processes and failure to verify the
turing. In response to the FDA 483 ob-
facilities (4). Similarly, contract facilities suitability of analytical methods. In its
are responsible for the drugs they produce servations, the company claimed that it warning letter, FDA told the firm, “FDA is
and activities they perform, regardless of was not a manufacturing facility. It said aware that many pharmaceutical product
the agreements in place with the product that it “is a private label distributor, which manufacturers use independent contrac-
owner or application sponsor. If a party has no manufacturing capabilities,” and tors, such as production facilities, testing
performs manufacturing activities, it is re- noted that it uses a contract facility. Its laboratories, packagers, and labelers. FDA
sponsible for complying with CGMP, and contract facility happened to be located regards contractors as extensions of the
no written instrument between the parties at the same address and shared person- manufacturer. You are responsible for the
can remove or shift this obligation. nel with the distributor. FDA put the firm quality of drugs you produce, regardless of
It is important to note that, while FDA on import alert and sent a warning letter agreements in place with product owners.
may uncover issues at a contract facility saying, “it is important to note that qual- You are required to ensure that drugs are
that extend to the owner, and vice versa, ity agreements cannot be used to delegate made in accordance with section 501(a)
FDA sends warning letters only to facilities statutory or regulatory responsibilities to (2)(B) of the FD&C Act for safety, identity,
it has inspected. However, FDA may add comply with CGMP.” strength, quality, and purity.”
the owner or contract facility as a CC line In another recent case, an owner con-
in a warning letter. In addition, findings attracted out product release testing, but When both parties violate CGMP
one facility may trigger an FDA inspection failed to ensure that the contract testing In one recent matter, both the owner and
at another facility. lab’s methods were validated. FDA issued contract facility received warning letters
a warning letter to the owner saying, “Your explaining their shared responsibilities.
Mistakes that a good quality assurance agreement with [contract The contract facility used the same fa-
quality agreement could prevent facility] does not specify method validation cilities and equipment for manufacturing
Since finalizing the guidance document, responsibilities … You and [contract facil- toxic car-care products and oral solution
FDA’s Office of Manufacturing Quality ity] have a quality assurance agreement re- drugs and received an FDA warning letter
(OMQ)—within the Center for Drug Eval- garding the testing of your products. You citing three CGMP violations. FDA also
uation and Research’s Office of Compli- are responsible for the quality of drugs you sent a warning letter to the product owner,
ance—has issued at least a dozen warning produce, regardless of agreements in place saying, “You are responsible for ensuring
letters that point out problems stemming with your contract testing laboratory. You that all your products are manufactured
from failure to fully comply with CGMP are required to ensure that drugs are made in accordance with CGMP, including
requirements and failure to communicate in accordance with section 501(a)(2)(B) of oversight of the manufacturing opera-
roles and responsibilities in contract manu- the FD&C Act for safety, identity, strength, tions conducted by your contractor … on
facturing relationships (4). The following quality, and purity.” your behalf. Contractors are extensions of
illustrate problems FDA sees when: the manufacturer, and you are required
• The owner and contract facility failed When the contract facility errs to ensure that your drugs are made in ac-
to follow their quality agreement FDA investigators found that a contract cordance with section 501(a)(2)(B) of the
• Owners failed to ensure contract fa- manufacturing facility had shipped drugs FD&C Act.”
cilities were CGMP-compliant to the United States without expiration In another situation, FDA found that an
• Firms failed to communicate issues dates. In response to the FDA 483 obser- owner and contract facility had released
or changes vations, the firm said, “As we understand, product even though neither the owner
50 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
nor the contract facility had conducted release tests. The FDA Conclusion
warning letter said, “You explained to our investigator that you Neither owners nor contract facilities can contract around
make finished product release decisions over the phone with your CGMP. FDA recommends that owners and contract facili-
contract manufacturer, based on whether test results meet pre-es- ties use quality agreements to help ensure that both par-
tablished specifications … During the inspection, you confirmed ties understand and document the actions they will take
that your contract manufacturers do not make your OTC drug to ensure compliance with CGMP. Without a well-drafted
products in conformance with drug CGMP. For example, you quality agreement, the quality of products manufactured
have released some drugs for which neither you nor your contract under contract may be affected and patient safety may be
manufacturers conducted release tests for identity and strength of jeopardized.
active ingredients. As a result, some of your drugs are distributed
without confirmation that they meet specifications for identity References
and strength of their active ingredients.” 1. FDA, Contract Manufacturing Arrangements for Drugs:Quality
Agreements, Guidance for Industry (CDER, Silver Spring, MD,
November 2016), www.fda.gov/downloads/drugs/guidances/
‘We didn’t think we needed to share that information’ ucm353925.pdf
Issues can arise through the failure to communicate a product 2. Federal, Food, Drug, and Cosmetic Act, United States Code, Title
quality issue. In this example, a contract facility was producing 21, www.fda.gov/RegulatoryInformation/LawsEnforcedbyFDA/
bottles of a sterile solution. Over a four-year period, it received FederalFoodDrugandCosmeticActFDCAct/default.htm
more than 1500 complaints about leaking, under-filled, and 3. Food and Drug Administration Safety and Innovation Act, Public
Law 112–144, July 9, 2012, www.fda.gov/RegulatoryInformation/
empty bottles. The firm investigated and attempted to correct
LawsEnforcedbyFDA/SignificantAmendmentstotheFDCAct/FDA-
the problem, but failed to notify the owner about the complaints. SIA/default.htm
In its warning letter, FDA said, “Your failure to follow the provi- 4. FDA, Warning Letters, FDA.gov, www.fda.gov/ICECI/Enforcemen-
sions of your quality agreement and appropriately notify your tActions/WarningLetters/default.htm PT
customer of the quality problems
discussed in this letter may have
delayed your customer’s ability to
take important actions to ensure
the quality, safety, and efficacy of
its products, including notifying
FDA via a field alert report (FAR)
NEARLY 50 YEARS
under 21 CFR 314.81.” SUPPORTING
In another example, a contract
facility used certain materials in PHARMACEUTICAL
production of a drug substance for
a sterile drug product. In addition
MANUFACTURING
to failing to thoroughly investigate
product quality deviations, the Today, our decades of research, development, nt,
contract facility did not communi- and experience in clean wipes manufacturing
cate with FDA about changes in its supports the most critical environments better
materials, even though the changes than ever before.
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proved by FDA before being imple- From controlled manufacturing areas to aseptic
mented. FDA issued a warning let- environments, our speciality wiping products
ter and sent a courtesy copy to the deliver the highest levels of quality for every
owner. “You and your customer, …,
application.
have a quality agreement regarding
the manufacture of … Regardless
of this agreement, you and … are Visit FGCleanWipes.com/pharma to see how oww
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quality, and purity.”
Pharmaceutical Technology MARCH 2018 51
Analytics
ensu res t hat t he opt i ma l qua l-
ity control strategy is in place to
monitor the continued efficacy
a nd sa fet y of a ny t herapeut ic,”
Wake says.
“Imag ine the sit uation where,
in the first instance, the degra-
dation route of a molecule had
not been assessed through forced
S
tability testing is essential for cal products, according to Russell molecules, which are expensive
maintaining the integrity and Crothers, supervisor, Sample Con- to produce, thus impeding their
quality of biopharmaceuticals trol Unit, Alcami. availability,” she adds.
and for assessing an accurate shelf- “With the right storage, appro-
life. It is an important aspect of priate shelf life determined, and Stability test design
quality control and is an important d ist r ibut ion met hods i n place, There are several important factors
step in evaluating product safety t he qu a l it y of ac t ive ph a r ma - to consider when designing and con-
and efficacy. It is also important for c e ut ic a l i n g r e d ie nt (A PI ) a nd ducting stability studies.
examining how critical quality at- d r ug pro duc t s is sa feg u a rde d,” “Sa fet y, qua l it y, a nd produc t
tributes (CQAs) of a drug substance Crothers says. efficacy work together in stabil-
vary with time under different envi- I n a d d it io n , u nd e r s t a nd i n g ity studies of APIs and finished
ronmental factors. potential degradation routes in drug products. Through stability
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tant for improving operational choose how to collect and when to nered to simplify mammalian cell count-
tasks, especially in the laboratory. The access their fractions. The system ing in laboratories (3). The new Corning
following is a sampling of the latest can be activated to collect based on Cell Counter uses technology developed
products available to optimize labora- slope, percent of buffer from pump B, by CytoSMART and offers enhanced
tory operations for biological products. pH, and detector signals. According speed for automated cell counting. The
to the company, front-to-back dis- device, which is exclusively supplied
Automated fraction collector pensing provides access to frac- by Corning, will be available through
The NGC Fraction Collector from Bio- tions before method completion for Corning´s global sales team and world-
Rad Laboratories provides flexibility improved speed of downstream analy- wide distribution network.
and collection capacity for analytical sis. Researchers can also choose the Cell counting is a crucial sub-
or preparative chromatography appli- type of collection vessel they prefer cultivation step in the cell-culture
cations when used with the company’s for each phase in a method, including workflow, according to the compa-
NGC Chromatography System (1). Fea- deep-well plates, tubes, bottles, and nies. Many laboratories still perform
tures include a benchtop Peltier cool- carboys (with prep-rack adaptors for manual cell counting using a hemo-
PRESSMASTER/SHUTTERSTOCK.COM
ing module for temperature-sensitive large-scale purification). Adding two cytometer or a counting slide viewed
biomolecules and an optional enclo- new fraction collectors to each NGC under a microscope. In comparison,
sure to protect samples from environ- System can further expand capacity, the Corning Cell Counter returns an
mental conditions while allowing full according to a company press release. accurate and precise digital cell count
access during a run. Because the en- in a few seconds. The device can
closure is optional, the same fraction Bioreactor control system accommodate the standard reusable
collector can also be used for reverse- Automated Control Concepts’ (ACC)
phase chromatography applications. Lab Owl is a bioreactor control and in- contin. on page 69
REGISTER FOR YOUR FREE TECHNICAL CONFERENCE AND EXHIBIT HALL PASS AT:
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Cold Chain Distribution
crossed the ocean by ship. It has histori-
cally been the Cinderella of pharma dis-
tribution, says Kennedy, but, IATA notes
that 3.5 million metric tons of pharma-
ceuticals are still shipped by ocean each
year, compared with 0.5 million metric
tons by air (3).
Over the past five years, ocean trans-
port has taken on much greater visibility
in the pharma industry. Cost competitive-
ness is one factor driving acceptance, he
says, since it is up to 80% less expensive
than air transport.
In addition, Kennedy notes, although
it takes much longer than air travel it is
Poseidon often more reliable, because there are far
fewer product handoffs. According to
T
ransporting sensitive pharmaceuti- Pharmaceutical transport typically control problems with air freight. As a
cals is a risky and complex business. combines different modes, explains Ken- result, Kennedy says, air cargo carriers
“The lower deck conditions within nedy. Air transport, prized for its speed began to set higher standards, establish-
a Boeing plane or a typical intermodal and flexibility, is used mainly for long dis- ing the IATA Center of Excellence for
freight container are a long way from tance, intercontinental distribution of the Independent Validators (CEIV) Pharma
the GMP-validated cleanrooms and con- most valuable therapeutics, he says, while program to interpret general European
trolled laminar-flow environments of the road is the most widespread method and Union and other good distribution prac-
AUN PHOTOGRAPHER/SHUTTERSTOCK.COM
pharma production environment,” says is also used to connect with both air and tices (GDPs) for air cargo (8).
Alan Kennedy, founder and executive di- sea freight. That same year, the EU extended GDP
rector of TEAM UP, an organization that Rail remains an insignificant factor, but regulations to cover controlled room
focuses on pharma supply chain issues. this may change, Kennedy says, as new temperature (CRT) products, which
According to the International Air “silk route” connections between Asia and must nominally be kept from 15–25 °C,
Transport Association (IATA), the global Europe are established (2). which only accelerated a switch from air
pharmaceuticals logistics market is valued to ocean transport, Kennedy says.
at $64 billion and is one of the most regu- Ocean: Cold Chain’s Cinderella? So far, most of the growth in pharma
lated, expensive, and fragile cargo mar- Ocean transport may conjure 1940’s im- ocean transport has been around rela-
kets in the world today (1), says Kennedy. ages of the days when most people still tively low value, high-volume products
60 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
pda.org/2018Annual
And, on March 22-23, 2018, PDA Education will host a choice of seven courses as part of the 2018 PDA Annual Meeting
Course Series to help you further advance your knowledge. Learn more and register at pda.org/2018AnnualCourses
From supply chains to supply networks: Poseidon aims to redefine pharma cold-chain logistics
Alan Kennedy, executive director of TEAM UP, shared perspectives on PharmTech: Are insurance costs more of an issue for sea than air freight?
Poseidon and ocean transport with Pharmaceutical Technology. Kennedy: Ocean transport insurance can sometimes be perceived
PharmTech: Why was Poseidon established and what do you hope to as a black hole by shippers, who are often more comfortable with the
achieve with the program? comprehensible and comprehensive insurance provisions associated with air
Kennedy: Like-minded individuals at the 2017 European Temperature freight. Shipping lines, for instance, tend to apply inconsistent liability limits,
Controlled Logistics Conference agreed that, in order for any degree of which, in any case, are invariably much lower than the typical value of a full
wholesale, across-the-board improvement in the pharma-cold chain, there container consignment of pharma products. It’s a problem that currently
would need to [be] more alignment between supply-chain stakeholders. prevents many otherwise suitable products from being shipped by water.
Poseidon’s model is built around some of the principles of supply-chain Poseidon is actively addressing this issue and has brought the insurance
collaboration and integration that are being successfully applied in industry into negotiations from the project’s start. As a result, Poseidon
other industries. Instead of a supply chain, Poseidon is a supply network can now offer a wide-ranging insurance framework specially devised to
that involves all of the stakeholders that are responsible for transporting provide satisfactory cover for all pharma shipment risks and values. Poseidon
pharmaceutical products. Currently, 19 companies are involved in the insurance will provide significantly improved coverage while demystifying
Poseidon project, including eight pharmaceutical manufacturers. the marine protection process.
Driven by pharmaceutical companies, the program is designed so that each PharmTech: Have there been any regulatory changes regarding ocean
pharma firm and its shippers, logistics companies, and suppliers sit around shipment or position pronouncements by the World Health Organization
the same table as equal partners. A network partner agreement governs the (WHO) or other global authorities on ocean transport of pharmaceuticals?
relationships between all these parties, and they work together as a single Kennedy: GDP legislation is indiscriminate, non-prescriptive and applies
team with common goals, rules, and performance incentives. universally to all transport modes. So, the same standards must be met by
Poseidon is putting together an end-to-end integrated network for pharma all (The IATA CEIV program is a translation of these regulations to make them
logistics. We hope that the model will serve as a template for pharmaceutical more air-freight-friendly).
companies in their quest for more efficient, more competitive, and more Although a high proportion of vaccines are currently transported by sea,
concerted supply chains that are fit for purpose in today’s rapidly changing the use of ocean freight has not yet been officially endorsed by WHO due to
environment. concerns surrounding the perceived implications of a ‘total’ loss situation
PharmTech: How are you connecting the many stakeholders who would (i.e., where a huge volume of urgent vaccines or drugs might be lost in a
be involved in ocean transport? single event). WHO is expected to review this position, however.
Kennedy: A cloud-based Poseidon Collaboration Hub enables members PharmTech: Have there been any detailed risk benefit analyses of ocean
to communicate in real time or whenever needed. Stakeholders around the transport performed recently?
world facilitate network communications, exchange ideas, disseminate news, Kennedy: Different pharmaceutical companies have launched proprietary
share information, access up-to-date documentation, and manage projects. pilot studies to ascertain savings and quantify results.
The Hub is also used for non-transactional network communications, for However, Poseidon is working with several pharma manufacturers to
meetings, and to store documentation. design and implement the largest ocean freight transport validation exercise
PharmTech: What types of technology (e.g., temperature and condition to date. This study will involve multi-container intercontinental shipments
monitoring) are being refined for ocean transport, and how would they differ of different pharmaceutical dosage forms (oral solid dosage forms, vial
from solutions that were developed for air transport? parenterals, and topical creams), which will be rigorously monitored and
Kennedy: The challenges of sea freight broadly mirror those of air, although documented. This exercise will be completed by June 2018.
some of the protection and monitoring equipment had to be adapted to the PharmTech: Are there types of pharma companies that tend to rely more
different time parameters and operating conditions. For example, one of our on ocean transportation? What interest are you seeing in the industry?
participants, DuPont, is currently exploring new cargo-cover materials for Kennedy: For the first time, the 2017 IQPC Temperature Controlled Logistics
ocean freight use. conference in London included a Sea Freight Focus Day. This event was sold
One of the advantages of sea freight is that it offers better shipment out, and 70% of those attending worked at pharmaceutical manufacturers,
visibility so that shippers can monitor the geographical position and physical almost all seeking to enter sea freight or to upgrade their sea freight usage.
condition of freight in real-time. At this point, Poseidon is only using Maersk Most of Big Pharma is already shipping some of its products by sea. However,
‘smart’ reefers and US-built Klinge ‘redundancy’ reefers. these companies typically deal in huge volumes that lend themselves well to
For air freight, the US Federal Communications Commission requires full container load (FCL) shipments.
transmitting devices such as data-loggers to be auto-switched off during Small- and mid-sized pharma companies, which contribute half the
flight for safety reasons. Although the loggers continue to capture data industry’s output, do not currently have access to a GDP-compliant less than
during the flight, this information can only be retrieved later. As a result, container load (LCL) service, also known as ‘groupage’ or shared container
there is reduced opportunity to receive alerts or to intervene quickly, to fix a service. Therefore, they are forced to send materials by air. We expect this
problem that has been reported while it is happening, such as an unexpected restriction to be lifted once Poseidon introduces its GDP-compliant LCL
temperature excursion that might compromise product quality. service later this year.
Current Challenges in
Bioprocesses Development
Ronald A. Rader
M
odern bioprocessing and antibody tion of upstream perfusion that are much reporting of high levels of concerns with—
manufacturing are mature fields; or somewhat bigger. and even fears of—perfusion versus batch
however, challenges remain, and bioreactors likely among those not using
the advances themselves often bring new Upstream continuous processing the technology. Many challenges remain
challenges. This is the nature of progress. Bioprocessing professionals clearly before the industry gains experience and
The current challenges are exemplified by see a number operational problems confidence in this option for continuous
the ongoing advances and industry adop- remaining with upstream perfusion upstream processing.
tion of technologies such as continuous versus conventional batch processing.
processing, the importance of modeling In 2017, a number of concerns were Downstream processing challenges
bioprocesses, increasingly seamless down- cited by more than 50% of respondents Downstream continuous operations, par-
scaling of processes, and other factors to BioPlan’s survey: ticularly chromatography, has more chal-
that are expected—and even required—by • Process operational complexity lenges; suitable hardware with built-in data
regulatory agencies. • Contamination risks systems are just starting to become avail-
Over the past 15 years, the industry • Upstream [process] development and able from suppliers. Downstream continu-
has evolved into a mature, productivity- characterization time ous bioprocessing was cited as the second
oriented segment. Of the dozens of trends • Process development control chal- single-most important bioprocessing trend
evaluated in the annual BioPlan Associates lenges. or operational area on which the industry
survey (1), productivity continues to show This daunting collection of concerns must focus its efforts. In BioPlan’s study,
the highest focus as an industry objective about perfusion persists despite it being in perceived need for improvements carries
(See Figure 1). This suggests that other op- use and marketed for multiple decades— over to facility budgets with interviewees
erational aspects must address industry including for commercial biopharmaceu- reporting an average increase of 8.8% in
challenges around improving productiv- tical manufacture—notably for Factor VIII. their 2017 downstream technology budgets
ity and efficiency. In many respects, perfusion may be viewed vs. 7.7% for upstream; 33.8% cited continu-
But to achieve successes, operational as a technology adoption model in biopro- ous chromatography as a “top area where
challenges must be worked out. As an ex- cessing that demonstrates the slow nature suppliers should place their efforts on.”
ample, continuous bioprocessing is one of, of adoption of rational, effective technolo- Adoption of continuous chromatogra-
if not the most, challenging area for process gies. BioPlan market research studies (1) phy, generally involving use of multiple in-
development. Continuous processing— have shown that approximately 5% of terfaced columns with integrated controls,
including both upstream perfusion and bioreactors use perfusion, with many of is growing more rapidly than perfusion
downstream continuous purification pro- these being feeder and not production bio- adoption; however, adoption has only re-
cessing—remains rare and elusive despite reactors. Further, while perfusion is seen cently started from a near zero baseline and
the fact these technologies have been es- by users as highly productive, often better is low. Combined with other downstream
tablished for some time. These challenges and cheaper versus batch processing, most advances (e.g., increasing use of mem-
particularly stand out when continuous using it in early manufacturing continue to branes in place of resin-filled columns, au-
LIGHTSPRING/SHUTTERSTOCK.COM
and conventional batch processing op- avoid its use in commercial manufactur- tomated in-line buffer dilution and column
tions are compared. Figure 2 shows survey ing, viewing the challenges as high and the packing, better resins, and more single-use
results when bioprocessing professionals risks significant, in terms of regulatory ap- and recyclable columns), downstream pro-
were asked to indicate issues with adop- provals. One challenge for perfusion pro- cessing is in many respects changing and
cess adoption is that single-use perfusion evolving more rapidly than upstream, but
Ronald A. Rader is senior director,
Technical Research, at BioPlan Associates, units only recently became available. This the adoption and integration into actual
+1.301.921.5979, info@bioplanassociates.com. lack of familiarity could be a factor in the bioprocessing remain slow. When asked
64 Pharmaceutical Technology MARCH 2018 P h a r mTe c h . c o m
Outsourcing Outlook
to cite the top downstream areas where Figure 1: Single most important biomanufacturing trend or operational
suppliers should focus their development area, 2014–2017.
efforts, disposable purification systems
were cited by 35.9% of respondents, fol- 0% 5% 10% 15% 20% 25%
lowed closely by continuous purification
16.4% Year 2017
cited by 33.9%. Geographically, European Manufacturing 18.9% Year 2016
Productivity/Efficiency 17.2% Year 2015
respondents are much more interested in 20.1% Year 2014
continuous purification compared with
those in the United States (44.4% vs. 25.3%). 12.3%
Continuous BioProcessing - 10.0%
But basic problems remain with Downstream
broader adoption of both upstream and
downstream continuous bioprocessing, 4.8%
Continuous BioProcessing - 5.7%
including the inability to integrate related 7.2%
Upstream
manufacturing systems. Currently, im- 9.1%
plementation of end-to-end continuous
bioprocessing, or even upstream or down-
stream segments, remains rare or nonexis- Figure 2: Selected concerns, perfusion vs. batch-fed processes.
tent, with at best one or a few unit processes Red is much bigger concern with perfusion. Blue is somewhat more
implemented as continuous. concern. White is at least somewhat of a concern, 2017.
Process scalability challenges
Contamination risks 37.0% 39.5% 76.5%
Bioprocessing modeling and understand-
ing of implications of changes in scale Process development control challenges 24.4% 52.1% 76.5%
remains another challenging area. The Process operational complexity 42.9% 31.1% 73.9%
industry has naturally concentrated on Upstream development and
26.1% 46.2% 72.3%
characterization time
scale-up, as drug product volumetric re-
24.4% 47.1% 71.4%
quirements increase as products advance Need for greater process control
bioprocessing. This is exemplified in the mented among products throughout a development and adoption of new tech-
use of down-scaled bioprocesses to vali- product line, particularly for bioreac- nologies create challenges that, sometimes,
date process biosafety, including reduc- tors and chromatography and filtration require years to resolve.
tion in virus titers from virus filtration systems. Bioprocessing professionals
and chromatography steps. The costs of regularly cite an expectation that bio- Reference
validating virus removal and inactiva- processing systems will seamlessly scale 1. E.S. Langer, et al., Report and Survey of Bio-
pharmaceutical Manufacturing Capacity and
tion would be too expensive and time- up and down. In addition, the users want Production, 13th annual (BioPlan Associates,
consuming if run for full-scale processes. to model or predict the operation of the 2016). PT
INTERPHEX
TAIGA/SHUTTERSTOCK.COM
2018
Planning VISIT PHARMTECH AT BOOTH 1430
• Meet the editors
• Review current issues of Pharmaceutical Technology
Guide
Plan Your Visit to
• Answer surveys
• Meet colleagues and peers
INTERPHEX 2018
STAY CURRENT ON TECHNOLOGIES AND SERVICES
Visit Pharmaceutical Technology sponsors that are
April 17–19, 2018 exhibiting at INTERPHEX 2018. See descriptions and
booth information on the following pages.
New York, New York
VISIT US AT INTERPHEX 2018
Avista Pharma
Solutions is a contract
development,
manufacturing, and Contec, Inc. is a leading manufacturer of
testing organization that understands what contamination control products for mission-
Chemic Laboratories, Inc. is a full service cGMP/
it takes to rapidly advance products through critical cleaning in manufacturing environ-
GLP contract analytical chemistry laboratory.
every stage of development. With over 200,000 ments worldwide. Our extensive product
Chemic provides an array of R&D and cGMP
square feet of laboratory and manufacturing line for cleanrooms and critical environ-
contract testing services including; Extract-
space in the US and UK, we offer a broad ments includes knitted, woven, and nonwo-
ables/Leachables analysis, CMC Method Devel-
suite of scientifically differentiated services ven wipes; presaturated wipes; sterile and
opment & Validation, Quality Control analysis,
ranging from early stage discovery, API and non-sterile wipes; disinfectants; mops; wall
Release testing, Raw Materials analysis, Com-
Drug Product development, and cGMP washing systems; sponges; and swabs.
pendial testing, Organic Synthesis/Formulation
manufacturing to stand-alone analytical and
Development & ICH Stability testing.
microbiology testing support. Chemic Laboratories, Inc., 480 Neponset St., Contec, Inc. • 525 Locust Grove, Spartanburg,
Avista Pharma Solutions • 3501 Building 7, Canton, MA 02021 • www.chemic SC 29303 • tel. 864.503.8333 •
Tricenter Blvd, Suite C, Durham, NC 27713 • labs.com • lcw@chemiclabs.com • www.contecinc.com • wipers@contecinc.com
919·544·8600 • www.avistapharma.com tel. 781.821.5600 • fax 781.821.5651 • INTERPHEX Booth #1234
INTERPHEX Booth #1153 INTERPHEX Booth #1372
Moderator
In this Webcast You’ll Learn
Rita Peters
■ Top quality goals and obstacles for 2018 for pharma
Editorial Director
quality teams
Pharmaceutical
■ How quality data can improve economic Technology
performance
Sponsored by Presented by
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Computerized
Systems Validation
In-house experts can help select the right systems and suppliers, making validation
and compliance easy, says Siegfried Schmitt, principal consultant at PAREXEL.
A. You are in a very typical situation where not all your auto-
mated systems are of a technical standard that make compli-
ance with the applicable regulations possible, unless you upgrade
system (or system upgrade) will help you to operate in compliance
with the regulations (i.e., what it takes to make sure that data
are trustworthy and your system is fully validated). In the URS,
or replace certain systems. It is an unfortunate fact that there are companies will specify what they expect from the audit trail (e.g.,
still vendors out there who make misleading claims, either out of it must be human readable, sortable, exportable, searchable, etc.).
ignorance, or worse, knowingly. The only party that can legally com- The URS also forms the basis for the testing requirements,
mission and operate a computerized system in a fully compliant namely the testing by the users. Users may be quality unit
manner is the system owner (i.e., someone within your organiza- personnel who need to verify that on an analytical instrument
tion). Only you know how you are going to use the specific system the series of injections for an analysis tally with the method,
and for what purpose. No vendor can do this for you. Therefore, or that there were no rogue injections. Only these people
automated system suppliers can merely offer to sell you systems will know what they are looking for and how they want to
DAMIAN PALUS/SHUTTERSTOCK.COM
that are designed and built in a manner that allows you, the cus- perform their review. Your system vendors are now tasked with
tomer, to operate them in a compliant manner (e.g., complying with providing you with a system that meets your needs, and not just
21 CFR R Part 11 or other regulatory requirements). a ‘one-size-fits-all’ solution.
Let me give you an example to clarify this: You may purchase Don’t be lulled into a false sense of security by sales
a system upgrade that provides audit trail functionality. Although promises; instead, make sure you have experts at hand who
the vendor gives you an audit trail as you requested, you may can help you select the systems and suppliers who best meet
choose not to activate it (perhaps because it slows the system your needs. Once you do this, you will find that validation and
down too much). Now you may be in a non-compliant situation. Or, compliance even with the most demanding regulations become
you decide to activate the audit trail, but upon review you find that not only possible, but exciting. PT
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