A Rational Approach for Setting and Maintaining Specifications for Biological and Biotechnology–Derived Products—Part 3 - The Biologics and Biotechnology Working Group on specifications of

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A Rational Approach for Setting and Maintaining Specifications for Biological and Biotechnology–Derived Products—Part 3
The Biologics and Biotechnology Working Group on specifications of the Pharmaceutical Research and Manufacturers of America presents new approaches to analyzing development and manufacturing data.


BioPharm International
Volume 21, Issue 8

ABSTRACT

This paper discusses an approach for the establishment and lifecycle management of biological and biotechnology-derived product specifications. The views presented are consistent with the concept of Quality by Design (QbD), in which critical quality attributes (CQAs) are distinguished from parameters used to monitor process consistency. Specifications and the corresponding limits as applied to CQAs serve to ensure that the product is fit for use, whereas control limits are a manufacturer’s tool to monitor shifts and trends in the manufacturing process. In the current paradigm, inappropriate use of specifications creates a disincentive for continuous process understanding; more suitable approaches to analyzing development and manufacturing data are discussed. Statistical methods are presented for deriving and interpreting data against specifications that better manage the risk to the customer of receiving product with diminished safety or efficacy, as well as the risk to the manufacturer of earmarking a satisfactory lot as unacceptable. The recommendations are presented as a rational approach to setting and maintaining specifications, while recognizing that their applicability may not be suitable in all cases, given the heterogeneity of types of regulated biological and biotechnology-derived products and their unique challenges.


Wyeth
The purpose of this paper, which has been developed by the Working Group on Specifications and Formulations of the Pharmaceutical Research and Manufacturers of America (PhRMA) Biologics and Biotechnology Leadership Committee, is to provide guidance on a lifecycle approach to setting global specifications for biological and biotechnology-derived products. In the pharmaceutical industry, specifications are legally binding criteria that a product must meet in order to be marketed. They ensure the consistency and quality of the product and help ensure that it is safe and efficacious over the shelf life of the product. Specifications evolve during product development and ideally should embrace future process capability. This is true for biological and biotechnology-derived products for which there may be limited experience at the time of regulatory filings (including the marketing application), and for which early commercial production often is necessary to gain a better understanding of product quality attributes, methods, and limits.

Parts 1 and 2 of this article, published in the June and July issues of BioPharm International, included four sections: Terminology; Stages of the Lifecycle of a Product; Components of a Biological and Biotechnology Product Specification; and Current Issues Related to the Development of Specifications. This final section describes a suggested approach for developing and maintaining a total quality system.

A SUGGESTED APPROACH FOR DEVELOPING AND MAINTAINING A TOTAL QUALITY SYSTEM

A rational approach to setting and maintaining specifications should incorporate the following fundamental principles:

  • A total quality system should seek to minimize risks to the customer and manufacturer alike. When in conflict, however, practice should err on the side of minimizing customer risk.
  • If possible, specifications should be established from sound scientific data and reflect fitness for use.
  • Specifications should be established to guarantee that the product is fit for use throughout the shelf life of the product.
  • Control limits are a manufacturer's tool to monitor shifts and trends in the manufacturing process, and to study the effect of process improvements.
  • Specifications should be set to control the average lot attribute rather than individual dosage units or measurements. This approach reflects current industry practice of mapping average quality attributes to population clinical response during product development.
  • A lifecycle approach should acknowledge that material and substantial information is necessary to establish specifications, and thus restrictive limits should not be set during development. In some cases, it may not be possible to set limits until post-licensure, after early product manufacture and test method experience have captured information adequate to set meaningful limits.
  • Product limits provide a basis for assessing product quality attributes at significant points in time, such as at release and at the end of shelf life. Limits should not be overused in studies that aim to explore process or product stability.

On the basis of these principles, the following guidance is recommended for setting limits for biological and biotechnology-derived products.

1. Capture scientific data during development to set limits that reflect fitness for use throughout the shelf life of the product.

With the goal of setting specifications that reflect fitness for use, development studies should be performed to identify quality attributes that may be linked to clinical outcomes, and to set release limits that guarantee the quality of the product throughout its shelf life. Setting specifications in this way requires a coordinated effort among the preclinical, clinical, and nonclinical development teams. The goal of identifying quality attributes that may be linked to fitness for use may be accomplished by using sound scientific judgment and by evaluating the historical performance of products with similar quality attributes.

Preclinical studies in animals or cell culture can help assess how changes in quality attributes may affect clinical outcome. These studies form the beginning of our understanding about which quality attributes may be clinically meaningful, and also can provide a basis for setting preliminary or final limits on those attributes. Clinical studies in target populations may be designed to explore or support ranges for meaningful quality attributes, which together with preclinical experiments form the basis of specifications. Nonclinical studies on final product should be designed to explore and define the properties of the product and analytical methods under conditions that are likely to occur during manufacture, testing, handling, and product shelf life.


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