Building a Business Case for Biopharmaceutical QbD Implementation (Peer Reviewed)

The author describes a methodology for developing a per product qualitative and semi-qualitative business case for applying QbD to a biopharmaceutical product.
Aug 01, 2012
Volume 25, Issue 8


The aim of this paper is to describe a methodology for developing a per product qualitative and semi-quantitative business case for application of quality-by-design (QbD) for a biopharmaceutical product. Previous authors have not frequently approached the business case topic on a per product basis. Instead, they have examined benefits across a portfolio for a company or aggregated across the pharmaceutical industry as a whole (1). In contrast, this effort focuses on a per product basis of business benefit estimate.

The primary purpose of a quality-by-design (QbD) business case is to demonstrate and elucidate the expected value that QbD is to deliver (2). Lack of belief in QbD's business case has been cited as a key challenge within pharmaceutical companies preventing successful QbD implementation (3, 4). Regardless, many companies already have adopted QbD concepts as their standard business practice for process and analytical development execution (5). Recently, momentum has increased based on QbD's recognized role as a new approach to improve product manufacturing and quality (6).

In 2010, FDA approved only six new biologics, giving few opportunities for QbD submissions (7). Overall, there have been few biopharmaceutical QbD submissions to date despite seven elapsed years from the first draft of the International Conference on Harmonization (ICH) Q8 guidance in November 2004 and longer since the first mention of risk-based quality approaches by FDA's Janet Woodcock in October 2002 (8, 9). Although submissions containing enhanced development data and parameter interaction studies have increased, there have been few, if any, design-space claims (10). Several biopharmaceutical QbD efforts have focused on retrospective QbD for licensed processes, leveraging larger amounts of manufacturing data, experience, and knowledge compared with processes for pipeline products (5).

Often, business cases are based on return-on-investment (ROIs) with minimal ROIs of less than a few years considered most attractive. During the early stages of QbD introduction, the business case was based on qualitative potential benefits in a few key areas: minimized manufacturing-scale development studies, fewer quality issues, greater flexibility to optimize postlicensure, improved patient-focus for the product, more clinically meaningful product specifications, and reduced effort in regulatory interactions. The business case needs to be updated based on the current level of biopharmaceutical QbD implementation maturity, considering that some of the potential benefits achievable for current pipeline products now may be substantially different.


Costs of goods

Selling costs for a product are lowered by lowering production costs, albeit not proportionally. In turn, production costs are fixed by Phase III clinical production processes. These processes are often developed to meet tight clinical trial timelines that do not permit substantial optimization for efficient licensed manufacturing, nor the ability to incorporate new process or analytical technologies (1). Simulated production costs, including indirect/fixed costs, for a typical aglycosylated protein ranged from $100–800/g depending on production host and selected yield assumptions (11). Lower production costs arise from reduced wastes (i.e., fewer rejected batches, deviations, or reprocessing), higher yields, and better utilization of assets (ie, greater overall equipment effectiveness) (12, 13). Specifically, the true aggregated cost of poor quality (COPQ) can often be greater than the more readily quantifiable cost of waste (14).

Development timelines

Development timelines directly affect the product's net present value (NPV). In one model, a 6-month delay to launch (type of product not given) translated to a $100-million loss in NPV (15, 16). In contrast, an 18 month acceleration increased NPV by $180 million by the model (15, 16). The average internal rate of return (RIR) for R&D for a biologic is 13% and NPV is $1.26 billion (15, 16).One author estimates a cost of $1 million in expenses for each day of product development and > $0.5 million in losses for each day delay in product commercialization (17).

Later parts of clinical phase timelines to final filing are primarily affected by assembly of clinical data, but timelines in early clinical phases can be highly affected by chemistry, manufacturing, and controls (CMC) activities. Even the availability of nonclinical bulk material can be rate-limiting because often the goal is to start pharmacology and toxicity studies as soon as possible (18). In addition, the entire timeline benefit associated with reducing CMC risks likely is under-estimated because some lurking CMC issues never are uncovered when clinical issues halt product candidate development.

Quantifying cost and timeline benefits

Table I: Sample matrix for quantifying biopharmaceutical QbD benefits.
Table I shows a sample matrix of QbD-related benefits and proposed steps for how to evaluate them. Ultimately all benefits can be related to a cost, either directly or indirectly, because timeline extensions are converted into opportunity costs. Direct costs can further be broken down into cost reductions or cost avoidance, based on the ability to either allocate fewer resources initially to complete a deliverable or request fewer resources to revise or redo a deliverable. Overall, the cost avoidance category serves as the most frequently estimated QbD benefit, primarily because it focuses on minimizing additional unexpected resources not already allocated.

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