Methodology. The limits of parameter variability discovered during method validation for a given analytical test are de facto verified
during the technical transfer. The design of a high-quality analytical variability matrix during method development and subsequent
validation is essential to provide satisfactory outcomes in parameters such as robustness and reproducibility at the time
of method transfer. This kind of expertise is challenging to transfer to the downstream laboratories in a limited time frame.
Side-by-side training is highly recommended to acquire all pertinent method details and the proper criteria to identify and
correctly attribute the source of parameter variation results, to ensure minimal interlaboratory result variations, or to
accommodate the use of equivalent, but nonidentical, analytical instrumentation. Additional considerations taken for the establishment
of equivalence of compendial methods between countries include, for example, content uniformity and moisture. The United States Pharmacopeia (USP) has three compendial methods for water determination <921> 1a, 1b and 1c, whereas the European Union uses mostly method
EP (2.5.12), which is equivalent to USP <921> 1c8; determination of content uniformity in JP General Test 109, even if it is considered an equivalent method to USP <905>, has differences in the way the results are calculated and reported.
Case Studies. Acquisition of truly equivalent instruments might mitigate potential variability in results later on. In one case, negotiations
to acquire equivalent instrumentation were not productive and equivalency between two instruments had to be established relative
to a third standard instrument. Eventually, the receiving laboratory agreed to consider purchasing an equivalent instrument.
Acceptance Criteria. The decision to set up acceptance criteria should be based on the receiving laboratory's ability to perform the method successfully.
The criteria for interlaboratory variability during method transfer should not be confused with method variability and must
be weighed against the precision of the instrumentation used for the particular method and biopharmaceutical drug specifications.
Interlaboratory variability acceptance criteria are method dependent and require careful examination of each individual method
documented in the transfer protocol. The handling of potential deviations from the acceptance criteria should be clearly defined
in the transfer protocol and a remediation plan should be instituted prior to initiation of transfer testing. All deviations
must be reported and documented as an addendum to the original transfer protocol.
In our experience, the preset acceptance criteria for one analytical method resulted in an out-of-specification (OOS) investigation
by the receiving laboratory. This situation could have been avoided if adequate acceptance criteria accounted for a realistic
analyst-to-analyst variability.
Drug Specifications. Specifications for a given biopharmaceutical might be considered too broad for the receiving regulatory agencies at the time
of product release. Specifications are intrinsically associated with the nature of the biopharmaceutical product and the precision
and sensitivity of the analytical method and instrumentation used; specifications also should be independent of analyst variability.
Suitable specifications are typically refined during the development of the drug product candidate and finalized before its
commercial launch; their acceptable ranges must be narrowed to meet or surpass acceptable ranges in accordance with the International
Conference on Harmonization (ICH) guidelines, in addition to those specified by the intended market regulatory agencies.
Analytical Reagents. Reference standards and critical reagents should be provided to the receiving laboratory to cover transfer protocol testing
and should include additional material for practice testing. For biopharmaceuticals, analytical reagents may not be commercially
available. A reasonable inventory supply tracking system must be established by the transferring laboratory to maintain a
log of critical reagents supply required to cover the needs of all release laboratories for long-term release testing. Additionally,
a regular supply chain must be established to the receiving laboratories. Not to be forgotten are valid import permits to
allow customs release of the shipped materials. Chain of custody procedures and environmental monitoring are customary for
all shipped critical reagents used for testing under a Current Good Practices cGXP setting (i.e., cGMP, cGLP, cGCP).
In our experience, unexpected situations have occurred and one must be prepared to handle them decisively. As an example of
critical reagent transfer surprises, the establishment of a good working relationship with the contracted international courier
was instrumental in preventing the loss of a dry ice shipment during a particularly hot summer week at a European port of
entry. To compensate for an unexpected delay in shipment relays caused by an airport controller strike, the courier contacted
its local office, rented a truck, and drove the shipment overnight through two countries to deliver the critical reagents
safely.
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