Professional Documents
Culture Documents
TRANSFER
Basics, Role of QA & Best Practices
Vaishali Yardi
Contents
• Technology Transfer Process and
• Overview
Oversight
• Types of Technology Transfers • Six stages of TT
• Pharmaceutical Product life cycle • Cross Functional Roles and Responsibilities
• Clinical to Clinical TTs • TT Project Structure
• Development to Commercial TT
• Stagewise Role of Quality in TT & Best
• Commercial to Commercial TT
Practices
• • Role of Quality
Types of Sites
• Internal-Internal TT • Best Practices
• Internal-External TT • Summary
• External-External TT
• References
Overview
• TT or Technology Transfer plays an important role in regulated pharmaceutical and
biopharmaceutical industries
• Expanded use of contract development and manufacturing organizations,
advances in manufacturing flexibility, increase in corporate mergers and
acquisitions, and enhanced regulatory complexity all contribute to the need for
technology transfers to maintain the continuity of drug supply
• In order to replicate systems safely, maintain high quality standards and meet
regulatory requirements, manufacturers have established approaches to
successfully transfer manufacturing and analytical technology and knowledge
from one site to another.
Overview
• TT uses a systematic approach to ensure the knowledge required to execute the
manufacturing process and product testing performed at one site can be incorporated
at a new site while maintaining understanding and product characteristics.
• This results in same, safe effective and consistent product being manufactured at both
the locations.
• Technology transfer can happen at all stages of product life cycle i.e., from drug
development through clinical trials to commercial release.
• PDA TR 65 on Technology Transfer covers the following:
• New product introductions
• Transfer of products being manufactured for phase III clinical trials
• Commercial release
• For TTs happening at an earlier stage of development, where process and product
knowledge is less understood, certain processes may not be required
Overview
• Involved parties in the technology transfer process should have established
systems for commercial manufacturing. Thus, standard requirements given below
are expected to be established:
• Equipment and Facility Maintenance
• Annual Product reports
• Lifecycle validation
• Complaint handling
• Continued process verification (CPV) programs
Types of Technology Transfers
• ICH Q10 describes TTs as new product transfers during development through
manufacturing and transfers within or between manufacturing and testing sites for
marketed products. This broadly includes the following:
• Analytical method transfers to an alternate laboratory
• Transfer to scale up a developmental product
• Transfer from a laboratory to a cGMP production environment
Continuous Improvement
Technology Transfer
Commercial Manufacturing
Product Discontinuation
Phase
Clinical Clinical Clinical Product
Phase 1 Phase 2 Phase 3 Approval
Pharmaceutical Product Lifecycle
• For driving reproducibility, elements of TT are performed at each phase of product
life cycle as knowledge of the process, product and testing increases.
• TTs can be described based on product life cycle phase like:
• Within clinical phases (Clinical to clinical)
• Transfers from Development phase (Developmental to commercial)
• Transfers within Commercial phase ( Commercial to commercial)
Clinical –Clinical Technology Transfers
• TTs at clinical stages should be developed, reviewed, and executed with
thoughtful consideration and should be phase appropriate from CMC perspective.
• TTs during these phases should address clinical patient safety and should start
building a foundation of future commercial production.
• During early clinical phases, involved sites should constantly consider future needs
related to scaling up and validating the manufacturing process, determining the
type of facility required, and defining the product, process and analytical
characteristics necessary to ensure Quality, Safety and Efficacy of product being
transferred
• Making knowledge management through early clinical phases is very important
especially because of complication arising in small material demands and possible
extended pauses for site inspections and regulatory approvals as clinical data is
being collected.
Development –Commercial Technology Transfers
• These TTs which begin when the product is in clinical phase III, involve transfer of full scope of
CMC requirements.
• By Phase III, the product, process and analytical development should progress in parallel with the
TT program to define the final CMC requirements for commercial readiness and process and
analytical validation. For example:
• Final dosage form and dosage should be known
• Drug substance manufacturing process should be established such that there are minimal changes in
impurity profile from clinical phase III to process validation
• Process validation and Critical Quality Attributes (CQAs) should be defined including characterization of
critical components and materials
• Initial stability for both drug substance and drug product should have been evaluated
• Risk assessments should be performed throughout the final development to determine the impact areas
for commercial manufacture.
• The objective of TT activity is to establish comparability between the Sending unit (SU) and the
Receiving unit (RU) processes or methods, and, as result, provide the regulatory authorities an
assurance to allow the use of the RU to supply clinical material or commercial inventory into the market
Commercial –Commercial Technology Transfers
• In these TTs, product is already being marketed and produced at an existing facility, yet
business needs might need it to be produced in another site
• This may need an operational scale-up or a scale-down
• Addition of a new market may require addition of an alternate packaging facility, which
world require TT of packaging operations.
• Alternate laboratories may also be used, requiring transfer of the analytical methods to a
new location.
• In TTs involving a marketed product, the original or current manufacturing location should
provide full CMC requirements with historic product and process knowledge, that
demonstrates manufacturing robustness.
• These types of TT may be an opportunity to implement process improvements at the
receiving unit, provided that those improvements align with business and regulatory
strategies for the TT.
Types of Sites
• Typically, 2 sites are involved in TT process
• Sending Unit: Location with current knowledge of product, process and analytical
methods
• Receiving Unit: location where the product will be manufactured or tested in the future.
• The use of contract manufacturing organizations (CMOs) and contract
development and manufacturing organizations (CDMOs) have introduced
variations in defining SU and RU sites during TT.
• Both SU and RU sites can be classified as external or internal. The type of site and
its relationship to the marketing authorization holder (MAH) impacts effectiveness
of knowledge transfer as well as overall TT team and governance framework.
• Internal –Internal Technology Transfers:
• Internal –External Technology Transfers
• External-External Technology Transfers
Types of Sites
Internal- Internal Technology Transfers
• A TT performed between locations of the same company or facility is considered as most
manageable in terms of knowledge transfer between the SU and RU sites because of the
following reasons:
• Most likely that both SU and RU sites are governed by the same Quality Management System
(QMS), have integrated document management systems and employ a standardized TT
procedure.
• If the company is transferring technology for an existing commercial product, historical data on
process or test performance should be readily available.
• If the internal SU and RU sites are in different geographical locations, an initial evaluation
will be needed to determine the potential impact of language, local implementation of
global QMS, import and export requirements and regulatory requirements.
• This TT may require additional budget for site-to-site interactions that allow SU to share
knowledge with RU and participate in initial manufacturing activities and SU
Types of Sites
Internal- External or External –Internal Technology Transfers
• The Marketing Authorization Holder may choose to work with an external company in
many different scenarios like,
• Product developed internally will be manufactured at commercial scale at an external
company, such as a CMO or CDMO, for cost or time-to-market purposes or due to limited
capability in internal facilities.
• Products developed by a CDMO will be manufactured at an internal site
• Commercialization was performed internally and transferred to an external company after
receiving regulatory approval or vice versa.
• Use of multiple manufacturing facilities will better meet demand and/or provide risk
mitigation for supply
• Expansion of product to a new market requires alternate global manufacturing capability
• A corporate acquisition or merger results in manufacturing consolidation
In these types of scenarios, the TT project manager has the additional challenge of managing
the TT activities across different sites, organizations and cultures.
Types of Sites
Internal- External or External –Internal Technology Transfers
• Unlike internal-internal transfers, any transfer to or from an external site may
involve difference in organization, Quality systems, and specific procedures.
• In some cases, the external organization may have competing priorities, which can
be difficult to discern
• Defining the differences in organizational structure, quality systems and business
priorities early can facilitate alignment on the TT boundaries and success factors.
• Agreement on the presence of SU SME (subject matter expert) at the external site
during the TT process to ensure successful knowledge transfer is an important
point that cannot be overlooked and should be documented in the appropriate
agreements.
Types of Sites
External- External Technology Transfers
• Often a Marketing Authorization Holder must manage a transfer between 2
external sites, which may also involve two different companies.
• This type of TT presents the highest challenge particularly if the two locations are
unfamiliar to each other (e.g., part of business strategy)
• If the external parties cannot interact, the MAH will need to act as SU for the TT
and facilitate the knowledge transfer to the RU
• Agreements on the presence of MAH and SU SMEs at the external site during the
TT process to ensure a successful knowledge transfer is an important point that
cannot be overlooked and should be documented in the appropriate agreements.
Technology Transfer Process and Oversight
Six Stage Technology Transfer Process
Stage Gate
Stage Gate
Stage Gate
Stage Gate
Stage Gate
Stage Gate
Initiation Planning Knowledge Readiness Execution Handover
Transfer
6
5
3
4
1
2
• Regulatory authorities expect companies to have a documented TT process that describes the steps to be
taken and the compliance requirements for each step.
• TT process used six stages and six gates
• Each stage 0f a TT serves a purpose and has identifiable outcomes. At each stage gates allow a steering
committee to determine whether those outcomes have been met and to decide if the TT should proceed.
• Stage gates at each of the six stages allow the steering committee to determine whether a TT is ready to
proceed to next stage.
• Often TT activities are performed in parallel than sequential in interest of business needs. Any information
during a stage indicating change in TT boundaries and/or assumptions should be immediately
communicated to steering committee.
Technology Transfer Process and Oversight
Stage Gate
Stage Gate
Stage Gate
Stage Gate
Stage Gate
Stage Gate
Initiation Planning Knowledge Readiness Execution Handover
Transfer
6
5
3
4
1
2
Once knowledge RU This stage
Potential RUs TT team The formal demonstrates
transfer of transfer closes the TT
are evaluated assesses the elements are and qualifies with
to identify TT risks and the detailed obtained, the TT the process at
requirements regulatory
sites with risk identifies team works in scale,
specific to TT approvals and
profile elements the readiness culminating in
begins allows normal
meeting critical to the stage to perform Regulatory
business the activities and operations to
knowledge submission begin
objective achieve
transfer and deliverables
TT team is overall required to
formed at RU timings achieve full
site operational
readiness
Cross Functional Roles & Responsibilities
TT Agreement
• All involved sites should document expectations, roles and responsibilities in a
formal TT Agreement
• Should specify the measuring units to be used in TT
• In case of internal-internal TT, shared procedure may be developed in place of TT
agreement
• This TT agreement or shared procedure provides information about the level of
involvement of each functional role at the SU and RU that will allow each site to
resource a TT team
Each site involved in TT should develop a cross functional team to execute the TT.
Each team should include a lead person who is an SME for respective functional
role.
Cross Functional Roles & Responsibilities
Function / Role Responsibilities
Business Strategy, marketing, Finance, legal and Sales
TT Project Manager Leads the overall TT process. There should be a project manager at each
involved site to support TT
Process Process chemistry and engineering, process performance qualification and
validation
Analytical Raw material, in-process controls, product, stability (development and QC)
Engineering Installation and qualification, equipment maintenance
Manufacturing Plant operations and EHS
Regulatory Health authority strategy and filing
Quality QMS Requirements, inspection readiness
Sourcing / Supply Chain Material sourcing, production planning and logistics
TT Project Manager (TTPM)
• Each site involved in TT should assign a Project manager for respective sites.
• This role requires technical knowledge across the functional areas as well as
knowledge of CMC requirements
• Serves as a potential point of contact and facilitates communication, knowledge
transfer and task completion
• In internal-internal TTs, a single project manager may serve for both SU and RU
functions.
• Wherever TT PM is located, this role is critical in facilitating constant
communication and should be the primary contact point for changes, decision and
team alignment.
TT Project Structure
Sourcing / Supply
TT Steering Committee
Marketing Authorization Holder (MAH)
Regulatory
Process
RU Management
Analytical
Oversight RU Engineering
TTPM Manufacturing
Quality
Sourcing / Supply
Stagewise Role of Quality in TT & Best Practices
Initiation Stage
Role of Quality
Quality in Document
Agreement &
• Ensure documented plan is in place that specifies who is
responsible and accountable for specific activities
TT & Best Contracts • Describe strategies in the charter that represent the full
scope of the project and avoid documenting only short-
Practices term needs
• Some aspects of charter may be included in contractual
agreement for clarity
• Draft an initial regulatory strategy, including expected
timeline for the submission.
Initiation
Topic Practice
Involve key functions • Involve key functions and personnel early to review the
early project requirements. This can help avoid missed
requirements or changes to the scope later in the project.
• Leverage expertise and lessons learned from involved
personnel
Ensure adequate • Ensure that the TT team includes all key functions and
Role of talent, expertise, and
focus on TT team
expertise pertinent to the project and the team members
have appropriate experience with transferring the product
Quality in • Ensure that the TT team personnel are either dedicated or
are made accountable to prevent inattention
TT & Best • Develop a backup plan to mitigate any potential loss of key
personnel
Practices Utilize Risk
Management
• Use risk management tools to assess and document risks
related to process requirements, facility selection (e.g., gap
assessment with process requirements) safety and quality
requirements
Initiation
Topic Practice
Utilize Risk • Document formally the assessment of the project and
Management company requirements for the product being transferred,
record identified risks, classification of findings, mitigation
strategies or actions required
Identify and plan for • Consider use of PAT as a component of process control
long led items strategy
• Identify long lead equipment
Role of • Critical workstreams have a clear plan from beginning to
Quality in end
• Identify and develop a plan for filling key project positions
TT & Best Develop Checklists
to ensure that personnel are in place and are trained in time
• Prepare a checklist to assist in leveraging lessons learned
Practices from previous TTs
• Use checklists for 1) Capability, Equipment, Material,
Quality, Safety, Personnel and 2) Documentation of
procedural , physical, automation and process
requirements
Planning
Role of Quality
• The MAH Quality function will work with the RU process function to
document in the product file and product specification, the
requirement that will ensure the quality, safety and efficacy of the
product.
Role of • In this stage, quality agreements must be developed concurrently and
Quality in executed, as required between the MAH and RU and vice versa and
additional GMP providers and external laboratories.
TT & Best • Based on target market, current stability requirements and
Practices commitments made to regulatory authorities, Quality will work with
the Process, Analytical, and Regulatory functions to prepare the
stability requirements
• Regulatory uses the stability plan to further develop the overall
regulatory time-line to ensure that all conditions of commitment are
met.
Planning
Role of Quality
TT & Best Engage vendors • Engage all vendors (equipment, excipients) early to identify
tentative lead times and begin drafting project timelines
• Ensure that the RU understands the quality requirements for
Practices raw materials and drug substances to ensure that selected
vendors will meet the quality requirements outlined in
marketing authorization
• Identify and process alternate vendors
Best Practices Planning
Topic Practice
Engage regulatory • Further define the regulatory strategy with project requirements
function • Discuss strategy with the TT team to ensure alignment
• Engage TT team to define variations that may cause deviation
• Proactively engage regulatory agency to support / advice on the
strategy
Create timeline that • Ensure that project timeline includes key milestones related to
Role of ensures sufficient time
for drafting and review
drafting, review and submission of filling and allows for regulatory
agency approval
Quality in of regulatory filing • Develop stability plan, making sure that all potential areas where
product needs to be marketed are considered
TT & Best • Coordinate activities and documents required for submission to
avoid extensive loss of finished product due to shelf-life
Practices restrictions while awaiting submission approval
• When developing timeline, anticipate that additional questions
that may need to be addressed after initial submission
Practices Provide RU with • SU should provide RU with historical data not already included un
historical data and the TT package. For an existing commercial process, for instance,
performance of this may include several years of commercial data such as release
product manufactured testing, CPV reports, annual product reports (APRs), deviations,
complaints etc.
Best Practices Knowledge Transfer
Topic Practice
Process comparability • Depending on project scope, the TT team may perform a
assessment and define comparability assessment and review learnings from the SU and
strategy MAH to define overall project strategy (i.e., scaling up, creating a
new process or proving equivalency)
• Develop a decision tree to consider whether process data is
sufficiently equivalent between SU and RU
• Plan for engineering batches or appropriate analyses to
Role of demonstrate comparability or equivalence.
Use Quality by design • A quality –by –design approach might be used to fully understand
Quality in approach the process design space before starting engineering batches
Practices
Best Practices Readiness Stage
Topic Practice
Use of risk • Use a risk register to ensure all potential risks are addressed and /
management plan for or a mitigation plan is in place before proceeding for ‘Execution’
risk mitigation • Systematically address process risks based on lab or
manufacturing data
Use a checklist • Use a checklist detailing all key requirements to ensure overall
process readiness
Role of • Create and share a regulatory submission tracker
Ensure all documents • Plan adequate time to draft, review, resolve comments on, and
Quality in are ready and approve the documents within the project timeline
approved • Consider all plant level documentation and regulatory submission
TT & Best documentation such as SOPs, Batch records, protocols, process
description, specifications for product release and stability
Practices documents
• Use templates where possible for consistency and make sure
authors and approvers are aware of timelines.
Best Practices Readiness Stage
Topic Practice
Ensure all materials • Ensure that material shipment lead times, site system setups,
are ready and tests and release timelines meet project needs
approved • Identify lead times early and share RU personnel aware of
timelines to test, receive, release and set up ahead of “Execution’
activities.
• Check in with the vendors to avoid last minute surprises
Role of Ensure all equipment • Ensure that equipment shipment lead times , installation and
is ready and validated validation timelines meets project needs
Quality in for qualification in next • If facility modifications or equipment installations are needed, plan
stage and coordinate use of shared resources (personnel and equipment)
TT & Best and estimate potential impact on the process
• Identify lead times early and make receiving parties aware of
Practices timeline, with an adequate buffer included, before activities will be
executed
• Check in with the vendors to avoid last minute surprises
Best Practices Readiness Stage
Topic Practice
Identify all parameters • Ensure that the final process is ready for the ‘Execution’ stage
of final recommended including all batch record instructions, SOPs, training needs, and
process for verification parameters for primary, secondary and support manufacturing
during next stage systems
• Ensure that process development studies are adequate and that
testing, and equipment qualification meet the requirements of
intended process, risk assessment and procedures
Role of • Produce data map for process data that shows all parameters
requiring control , the means of control e.g., batch record,
Quality in automated controls, in process controls etc. and means of
recording
TT & Best • Use the data map to enable process monitoring and to assess
whether access to data in a timely manner will present challenges
Practices during the next stage.
Perform engineering • If any final changes are made to the process, or development was
run on the final not performed on the final intent commercial equipment, perform
commercial process an engineering batch to verify the final intended process prior to
proceeding to next stage
Best Practices Readiness Stage
Topic Practice
Establish a plan for • Plan to draft, review and approve filing for on time submission
successful regulatory within the project’s timeline and launch requirements. This plan
filing should be detailed in the submission tracker and regulatory strategy
documents
Minimize handoffs • Ensure that personnel are adequate to proceed to the next stage
between functions and and that loss of personnel does not impact the overall process
Role of keep personnel on the • Avoid reliance on contractors for all project activities. If contractors
project throughout are necessary, use a mix of fulltime employees and contractors to
Quality in ensure sufficient internalization of key process information
• Maintain key staffing throughout the project. Use same set of
TT & Best personnel throughout development, process verification and
commercial stage
Practices Take sufficient time at • Use stage gate, risk management tools or gap analysis, and
each stage to identify checklists to plan for all requirement are ensure that tasks are
key requirements completed prior to proceeding to next stage
• Formally assess risks of any open or incomplete action to
understand potential impact on next stage if not closed
Best Practices Readiness Stage
Topic Practice
Take sufficient time at • Fully investigate any process failures or results operating on the
each stage to identify edge of process design and, as a team, identify if development
key requirements needs to revisited prior to proceeding
Ensure supporting • Trouble shoot, test and qualify key equipment for readiness to
systems are ready for begin executing activities to ensure that software, change
new process management, spare parts, cleaning, maintenance, calibration,
Role of supporting functions, and resources ready for new process
• Test batch reports, release process, validated electronic systems
Quality in (SAP, ERP etc.) during engineering batches to avoid PPQ surprises
• Ensure that testing facilities have qualified or validated analytical
TT & Best methods as required and will be able to test according to the agreed
upon schedule
Practices Hire personnel soon • Ensure that functional managers and steering committees follows
enough to train before up in time for resource approvals, hiring and training in advance
they are needed • Involve manufacturing operators in automation-testing, SOP
preparation, batch record and automation development to promote
learning
Best Practices Readiness Stage
Topic Practice
Conduct Operations • Finalize work instructions for the start of the batch manufacturing
Training • Ensure that the operators have sufficient time to train on the work
instructions.
Establish batch release • Ensure alignment among Process, Quality and Manufacturing
process functions on the batch release process. Address such questions as
• What batch reports will be reviewed?
Role of • Will the intermediates be released or processed straight through
• Will the batch records be reviewed on the floor as completed
Quality in • Which forms will need to be approved and how are all requirements
of change control satisfied?
TT & Best • Are trucks scheduled if outside the normal hours?
Practices
Role of Quality Execution Stage
• The Quality function is integral throughout the Execution stage as it
releases material for use
• Quality is responsible for product release, including batch record
review and overall batch disposition in accordance with site quality
procedures
• Quality is also responsible for supporting the review and approval of
Role of all documentation for the PPQ, including protocols, reports, batch
Quality in records, forms, results, change controls and deviation and
investigation close-outs
TT & Best • Quality function is expected to close out the QRM associated with the
TT at the end of the PPQ
Practices • At this stage, Quality performs final inspection readiness activities in
anticipation of the regulatory filing activities which depending on TT
type, may trigger a Pre-Approval Inspection (PAI).
• A mock inspection (in depth audit) of RU to identify issues to be
addressed before filing a submission
• Completion of PAI may be marked as end of execution stage
Best Practices Execution Stage
Topic Practice
Create technical • Ensure that the SMEs are on the floor prior to execution, to provide
support plan for training and trouble shoot if needed
qualification • To ensure knowledge transfer from SU to RU and to resolve any
issues or escalate in timely manner to avoid delays
• Involve technical personnel during qualification for technical support
of new equipment if issues arise and to monitor future improvements
Practices Perform a trial run • Conduct a mock or a trial run with a water batch or rejected material
to ensure equipment readiness and adequacy of operations training
• Ensure the production team has sufficient time to practice using new
equipment, parameters, batch record and process steps beforehand
Best Practices Execution Stage
Topic Practice
Call a readiness • Ensure the production team is clear on process requirements prior to
meeting before execution
running qualification • Review and /or update the control strategy
batches • Avoid introducing new variables not challenged in previous stages
• Plan ahead and reference best practices on engineering run, in pre
batch readiness meetings and during operators training
• Use risk assessment to address any new variables that cannot be
Role of avoided
Prepare filing and • Provide regulatory authorities with documents that support the filing
Quality in plan for questions
from regulatory
as they become available, in alignment with the submission tracker
• Identify and prepare SME to address questions received from
TT & Best authorities regulatory authorities after initial submission
TT & Best
Practices
Handover stage
Role of Quality
• As a part of Handover stage, the MAH Quality function establishes the
quality management review process which should involve both the RU
and the SU.
• The quality agreement may need to be updated to address everything
associated with commercial manufacture
Role of • Quality will ensure the closure of all documentation from the TT,
Quality in including change controls, validation reports, deviation and CAPAs.
• It may also play a role in identifying lessons learned from the
TT & Best Execution stage that should be incorporated in future training
operations team to improve process quality
Practices
Best Practices Handover Stage
Topic Practice
Host a formal • Hold a formal meeting between the TT team and the post transfer
handover meeting operations team to ensure overall readiness of the process
• Handover key documents, process understanding and learnings
• Provide a regulatory dossier and communicate any post marketing
commitments made to regulatory authorities
• Have the TT team provide an overview of new equipment, launch
timeline, commercial forecast, manpower requirement,
Role of procurement requirements, open actions from risk assessment,
process improvement and lessons learned
Quality in
TT & Best Create a long-term
training plan for
• Prior to handover, assess whether the production team needs
additional training on the process and equipment
Practices production • Use final lessons learned to revise and maintain the training program
• Include adequate hands-on training with SOPs and batch records