Pharmaceutical Technology Transfer Practices into Design Control Systems for Combination/Convergent Products Roy Fennimore Research Fellow Product & Process Scientific Solutions (P2S2) Johnson & Johnson INTERPHEX New York City, NY 24 April 2013 1 “I don’t get it. We design one pill good for 240 maladies and Marketing tells us there’s a design flaw.” 2 The 5th Wave By Rich Tennant “Oh sure, I’ve used historical data analysis in the past, but lately it’s been pretty much hysterical data analysis at work.” 3 Agenda Adapting Pharmaceutical Technology Transfer (TT) into a Design Control System Integration Strategy Linking Pharmaceutical Development to the Design Control System Technology Transfer Guideline: Key Concepts for Integration New Product Development Process – Roadmap and Guides Translation from Pharmaceutical to Design Control Deliverables Design Control Waterfall Diagram vs. Pharmaceutical Deliverables for Integration Review Report Outlines: Such as Product Development, Analytical Test Methods and Process Transfer, if time permits 4 Overview A high level view where Technology Transfer integration aligns with Design Control (DC) and the New Product Development (NPD) Process Review Report Outlines: Such as Product Development, Analytical Test Methods and Process Transfer, if time permits 5 Purpose Provide an overview of how pharmaceutical technology transfer deliverables and best practices can be integrated into the Design Control (DC) System and the New Product Development Process for Combination/Convergent Products 6 Integrating Pharmaceutical Technology Transfer (TT) into Design Control (DC) for New Product Development Process Objective: The New Design Control System should be compatible for device development and device/drug combination/convergent product development as well as compliant with QSR/FDA GLP/GMP/ISO regulations, standards and applicable international regulations etc. 7 Adapting Pharmaceutical Technology Transfer into Design Control (DC) for New Product Development Process (NPD) Leveraging: Literature search for “Technology Transfer (TT) Processes” and benchmarking can be used to identify relevant pharmaceutical development deliverables to include within NPD Process/Design Control System Many of the general (TT) practices are applicable and can be adapted for both device and combination products, –e.g., characterization of product and process / summary reports Must realize if your company has a different business model and development process from pharmaceutical companies Could utilize Design Control terminology as the foundation for DC system – The development of any type of product is also similar to the Process Design Excellence or Six Sigma Practices – Pharmaceutical requirements can be integrated throughout the design control process Timing and ownership can be different in terms of Design Transfer Project Teams of NPD can own the design to sales launch 8 Benchmarking – Some Best Practices & Applications Product development roadmap and guidelines Streamlined system with compliant, clear, concise documents Program management and team structure Support/maintenance for the product development system Technology transfer requirements and procedures Integrated drug-device requirements Integrated Design/Process Excellence, Six Sigma Practices 9 Integration Strategy for Pharmaceutical TT Deliverables Resources, Organization, Stage Gates, Dashboards, Business Practices Design Input: Product Description (Profile and Specifications) and Toxicology (including Toxicology Animal Studies) Design Output: Product/Process/Packaging Documentation Design Verification: Analytical, Assays, Stability Studies including Packaging Stability Testing Design Validation: Assay Validation, Regulatory Requirements including filing and approvals, Clinical Trials Product/Process Validation: Pre-formulation, Formulation Development, API, Process Development, Scale-up, Process Validation, Facility Start-up and Validation, Pre-Approval Inspection Preparation and PAI. Technology Transfer: Technology Transfer Plan, Updates and Transfer 10 Example of Pharma Integration Management & Team Approach 1. Develop communication strategy Communicate the roles and responsibilities of pharma integration especially in the areas that overlap Generate a list of pharmaceutical deliverables for integration and reach agreement with the teams Communicate the timing of deliverables Regular updates to the management team 2. Identify pharma gaps and leverage best practice pharma deliverables from Literature and Benchmarking Identify gaps - VOC, project lessons learn (e.g. On-going Device projects), mapping, internal audits or external observations Identify leveragable material from literature – Pharmaceutical/Medical site visits, if possible (process, deliverables, guidelines, SOPs, etc.) 3. Generate pharma related requirements and provide these requirements to respective teams Develop a pharmaceutical deliverable integration matrix Partner with respective teams based on the pharma deliverable integration matrix 4. Coordinate with other teams in company method generation Provide content expertise Recommend what needs to be integrated and what could be stand-alone documents Draft/Review pharmaceutical specific sections for the integrated ones Draft/Review specific pharmaceutical methods for stand-alone documents if required 5. 6. Coordinate with other teams in the reviewing process Create internal guides Draft/Review the ones that require the pharma deliverables 7. Provide training after approval of method generation 11 Linking Pharmaceutical Development to Design Control Pharmaceutical Product Development can be Viewed as Two Separate but Integrated Processes Pharmaceutical Product Development “Claims” Development Discovery Commercialization “Process” Development “Claims” development – Integrates clinical, regulatory, and marketing strategies – Optimizes claim structure, product positioning and promotional messages “Product/Process” development – Integrates chemistry, formulation, and manufacturing – Optimizes product/process specifications, cost and production 12 Pharmaceutical Product Development and Device Development Can Differ in Several Key Areas • • • Product development cycle time – Pharma development can be as long as ten years – Device development is usually less than three years Product design and specification – Drug products are defined by the results of clinical trials • Discovery-driven and little can be done to modify the drug substance to meet customer needs • Process focuses on maximizing what is discovered to get best label for given indication • Development more like a legal process as in “claims” made – Devices are specified to meet market needs • Products can usually be engineered to a much greater degree • Process focuses on optimizing commercial potential by focusing on trade-offs between options • Development can be heavily customer-driven Magnitude of development effort – Since pharmaceutical drugs take so long to develop and typically require over $500M to bring to market, a significant number of personnel are involved with a project (as many as several hundred) – Device development can be tailored to the size of the project—from minor upgrades to significant technology implementations; however, their size is usually no where near that of drug 13 development Technology Transfer Guidelines – Key Concepts for Integration Technology Transfer Strategy and General Checklist Pharmaceutical Development (PD) Summary and PD Report after Transfer Analytical Development (AD) Summary, AD Report after Transfer Product/Process Transfer Report 14 CDA1 Definitions Technology Transfer Strategy and General Checklist The Strategy is a written document that outlines the agreements made between Development and Operations concerning the technology transfer. The “Checklist” is a detailed list of development requirements and corresponding documentation that guide the collection of technology transfer knowledge for a specific project. Analytical, Pharmaceutical Development Summaries and Reports The summaries are a compilation of technical product knowledge, according to the strategy established, takes place during the NPD phase. The activities performed during NPD phase are within the R&D environment and in accordance with Operations expectations. Reports document production scale development activities that occur after the actual transfer from Development to Operations has taken place. Product/Process Transfer Report Locks in the core product and process information prior to manufacture of the registration batches and to document comparability between the new product developed in R&D and the final to-be-marketed product. 15 Slide 15 CDA1 May want to consider making this into 3 slides (or have each definition fade in so that you focus the viewer on what you want him/her to see/read. CAllman1, 2/10/2009 Technology Transfer (TT) Pharmaceutical Overview Define & Measure Initiation Analyze Starting Gate Commercial Concept Evaluation Design Verify and Validate Product Defined Gate Product and Process Development Monitor Product Evaluated Gate Closing Filing and Launch Product and Process Evaluation Registration Batches •API Characterization, •Pre-formulation, Formulation, Early Process Dev TT Start (Sourcing Decision) •Route of Administration •Early Analytical Dev •Early Stability •Technology Transfer Strategy and Checklist •Pharmaceutical Development Summary •Analytical Development Summary 1 •Product Transfer Report File PAI •Pharmaceutical Development Report •Analytical Development Report Product Development File 16 Manufacturing Operations File I Linking Pharmaceutical Product Development to Design Control (Example of a Roadmap) Conc ept Pha se Fea sibility Ph a se Stage 0 Pr oof of Conce pt Di scover y Im plem entation Pha se Dev elopm ent Pha se Stage 2 Dose & Scale Def Stage 1 Pr oduct & Pr ocess De f Stage 3 Efficacy & M FG Stage 4 Lice nsure & Launch Ba se Bu sin e ss Pha se Stage 5 Li fe Cycl e M anagement Design Inp ut - Product Specification T arget P roduc t P rofile Define P roduc t S pecific ations Risk Manage ment – Animal Studies In Vitro Toxicology G LP Starts A cute Toxicology Animal S tudies Chronic Toxic ology Animal S tudies . PA I Preparation Process Devel opme nt and Valid ation GM P Star ts P re-Formulation Facility S tart-up & Validation Form ulation Development API PAI A ss ay V alidation De s ign Fr eeze P rocess Development & S cale up Design O utput Commercial P roduction P roduc tion S upport P rocess V alidation Produc t/Proc ess/P ac kag ing Doc um ent atio n • • • • • Pharma ceuti cal D ev elopment Summ ar y • Anal yt ic al D ev elopm ent Summa r y Product D ev elopment File (DH F) Product Transfer Report Pharma ceuti cal D ev elopment Report Anal yt ic al Dev elopm ent Report Design Ve rification – Test Meth ods & Stab ility Studies A nalytic s Development Develop & Qualify Charac terization & Releas e As says for RM, P roc ess , & P roduc t T rans fer Ass ays Anal yt ic al D ev elopm ent R eport Anal yt ic al Dev elopm ent Summa r y P roduc t S tability S tudies P ac kaging S tability S tudies S tability Study Updates Start Final Stability Study Design Valid ation (P rod uct) – Safety and Efficacy Expir ation Date Es tablis hed Regulatory Filing P reparation and Submis si on IND Subm iss ion NDA Subm iss ion P has e II T rials P has e I T rials Re gulator y Approval P has e III T rials FIH P has e IV T rials Pivotal Tr ial Starts Design T ransfer/ Design Cha nge T ec hnology T rans fer P lan (TT P ) TTP Update TTP Update T ec hnology T rans fer Technolog y Transfer Strateg y Planning/Review Phase Review • Product Dev . Plan (Clinical, R egulator y, CM C, etc.) Phase Review • PDP Updates Phase Review • PDP Updates • Launch Strateg y Phas e Review Phase Review 17 Phase Review Generate a Roadmap for New Product Commercialization Process • What it is…. – Could be a one-page overview of New Product Development Process for Commercialization – Captures steps, timing and sequence, phase deliverables, and roles and responsibilities – Describes timing and sequence of Design and Business Reviews – Can be aligned with Process Design Excellence / Six Sigma methodology • What is it used for… – Used by project teams as a template for repeatable and disciplined project planning and management – Can serve as a reference to management oversight 18 The Roadmap should illustrate a high level commercialization process, but also serve as a tool for project planning & execution. Main Themes: Must be relative to your system today, the most unique aspects of this process are the phases. The phases should be well defined and can be staged to promote technical excellence. For example, the first phase may focus on defining the scope of the project, gathering user requirements, and translating these into technical requirements (specifications targets) prior to selecting a concept. For example, the next phase could be mainly about project planning and concept selection. The third phase could be about developing the concept and processes used to make that concept into a final design. Business reviews could be separated from the technical design reviews to promote the Technical Design Reviewers focusing more on the technical aspects of the program. The Design Reviews and Project Management Reviews can be scaled for simpler programs. 19 Develop Internal Guides for New Product Development to Commercialization • What is it… • What are they used – A guide for each step for… on the Roadmap, it – Drive consistent and could describe tasks, repeatable project inputs, outputs, bestplanning and practices, etc. management – Linked to Quality – Capture key System requirements planning – Linked to applicable assumptions and Process DEX /Six Company’s bestSigma Tools practices – Serve a primer and training reference for the NPD process 20 Design Control Waterfall Diagram vs. Pharmaceutical Deliverables for Integration User Requirements Design Input – Output Technical Product/Process Development Reports Design Characterization and Design Summaries Requirements Analytical Development Summary Technical Design Input Pharmaceutical Dev Summary Design Process Final Documentation for Product & Process Specifications Design Output Design & Development Planning Technology Transfer Strategy and Checklist Verification and Validation Summaries Design Verification Design and Development Planning Design Validation Medical Product Validations Including: Facility Validation Cleaning Validation Test Method Validation Cleaning, Facility, Analytical Validations Including: Method, Equipment Cleaning, Facility, Analytical Method Product/ Process Transfer Product Report Transfer Report Pharmaceutical PharmaceuticalDev Dev Process Validation Technology Transfer of Knowledge from R+D to Commercial Operations Report Report Analytical AnalyticalDev DevReports Report Analytical Method Transfer 21 Integration of Key Pharmaceutical Reports/Summaries Concepts 1. Summary of the development history and any changes since development. 2. Documents comparability of the product and process from development to commercialization. This is accomplished in the summaries by documenting that the impact of any relevant design changes does not affect the validity of the verification and validation activities. 3. Documents the critical links between the product and process from pivotal clinical activities, registration, and finally to commercialization. This can be documented through an equivalency assessment in the summary or report. 4. Justification and rationale to support the final commercial product and manufacturing process through an equivalency assessment in the summary or report. 5. Locks the critical product, process and analytical information prior to the manufacture of initial registration and ISS batches. This can be accomplished through the successful completion of validation and summarized in the process validation summary or report. 22 Technology Transfer General Checklist Detailed List could have 10 more Items per Subject Bullet General Product Information Drug Product Active Pharmaceutical Ingredient (API) • • • • • • • • • • General API Information Physical Description Characterization and Proof of Structure API Manufacturer Synthesis/Method of Manufacture API Process Controls Reference Standard Specifications and Analytical Test Methods API Container Closure System API Stability • • • • • • • • • Components Composition Specification and Test Methods for Inactive Components Manufacturer Methods of Manufacturing and Packaging Specifications and Test Methods for Drug Product Drug Product Container Closure System Drug Product Microbiology/Sterility Drug Product Stability 23 Pharmaceutical Development Summary Outline Executive Summary: • Comprehensive summary focusing on the development of the drug product and manufacturing process. Introduction: Development Strategy: • Describe of the decision path and supporting rationale and justifications taken in during the development of the drug product and manufacturing process. Include all issues and risks. Information on the API: • Chemical Structure and molecular formula. • List special properties relevant for the product and/or process development. • Specifications Drug product: • Formula rationale for excipients (include sensitivities such as heat, light, etc.). • Formulation history. • Specifications/suppliers of excipient. • Product specifications. Manufacturing process: • Manufacturing process rationale. • Manufacturing history Process Flow Diagram with process parameters and acceptable ranges. • Manufacturing equipment requirements and principle of operation. • In process controls. • Cleaning assessment Packaging: • Rationale for immediate container selection. • Immediate container description/supplier/specification . Batch overview: • Development batches trending table to include: • Batch number and size • API lot number • Where and when batch was made • Purpose of the batch • Analytical result of the batches Critical parameters: • Discussion of critical parameters identified from lab and pilot scale. • Process Capability Report/Results References: References to detailed reports that are identified in your checklist. 24 Analytical Development Summary Outline Introduction: • General information on the API: chemical structure, name and code number. Impurities and degradants: • Rationale for the selection of the specified impurities and degradants (if applicable). • Provide historical data from explorative and full product development. Analytical methods: • Rationale for the choice of the analytical method for a particular specification and also provide in this section: • Analytical method evaluation (ring test) and validation • Analytical Method Development Report • Robustness testing • Drug Product stress degradation studies • Analytical Method transfer reports Instrumentation: • Rationale for critical instrumentation parameters, reagents, utilities and other relative instrumentation information. Control of change: • Description and rationale for method changes. Training: • Training requirements and support on all methods used for the testing of raw materials, active ingredient(s) and finished drug product. Conclusion: • Conclusions resulting from the available method development data supporting the methods presented in the regulatory filing. 25 Product/Process Transfer Report Outline Pharmaceutical development summary: • Brief description of the drug product development history. Scale-up summary: • Brief description of the manufacturing development history from pilot scale to full scale. Product Composition: • Comparison of each separate ingredient in the product and corresponding quantitative composition between the development site and manufacturing site. • Explanation of any differences encountered between the development site and manufacturing site. Raw Materials: • Comparison of each separate raw material and corresponding code number, supplier, trademark and specification reference between the development site and manufacturing site. • Explanation of any differences encountered between the development site and manufacturing site. Immediate container: • Comparison of each immediate container component, supplier and specification reference between the development site and manufacturing site and any differences encountered. Product specifications and test methods: • A summary table identifying the test, specification and corresponding analytical method. Manufacturing process: • Comparison of the manufacturing equipment, operating parameters and IPC limits for each step of the process between the development site and the manufacturing site. • Explanation of any differences encountered between the development site and manufacturing site. • Process flow diagram • Manufacturing instructions Packaging: • Packaging description including reference to specifications. Validation: • Process and cleaning validation strategies and/or reports • Sterilization validation strategy and/or reports (if required) Stability: • Registration stability strategy and stability protocol. Conclusions: • Conclusions concerning the scale-up experiences. • Development team and Operations team approval signatures. 26 Pharmaceutical Development Report Outline after Transfer Manufacturing process: Purpose/Scope: Product description: • Short description about the product and attributes. Executive summary: • Clinical and commercial formulations overview. • Manufacturing process scale-up overview. Active pharmaceutical ingredient: • Include molecular structure, weight and formula, relevant physico-chemical characteristic and specifications Drug Product: • Formulation development history and equivalency between clinical formula and commercial formula (if different). • Purpose, rational and characteristics for each excipient with the corresponding supplier and specification references. • Qualitative and quantitative descriptions for each formulation. • Rationale for all product specifications. • • • • • • Manufacturing process from pilot scale to full scale history (including biobatch). Process flow diagram Batch overview table with: Batch number, size and purpose API lot number, location and date of manufacture Identify equipment train and equivalency with pilot scale List critical parameters with operating ranges Provide acceptance criteria and inprocess ranges Cleaning validation: • • Description of cleaning validation Description of cleaning method and relevant results and criteria. Conclusion: • Conclusion on robustness and control of the final drug product and manufacturing process including stability summary and shelf-life statement. Provide equivalency with bio-batch and/or pivotal clinical batch(es). References: 27 Analytical Development Report Outline after Transfer Purpose / Scope: Product information: • Short description about the product. Executive summary: • Submitted methods overview. • Methods classification with regard to their use for stability and/or release purposes. • Transfer process status to the QC Operations sites with references to the transfer documents (your checklist). Method development: • Selected methods rationale. • Experience summaries of the stability development groups and the QC Operations sites when applying the methods. Specifications: • Specifications with the justification. Stability: • Stability summary or report. Control of change: • Applied control of change and of the communication with the regulatory bodies overview. Conclusion: • Conclusions resulting from the available method development and transfer data supporting the methods presented in the regulatory filing. References: • Method descriptions, robustness and validation report references. 28 • • • • • • • • • Key Outputs/Documents for Technology Transfer (TT) of Knowledge for Combination/Convergent Products Process Overview and Process flows - Details of Process Description and format (Excel or Visio) for process flow diagrams SPC Strategy – Control Points, etc. Characterization Strategies/Studies/Reports CTQ Flow Down and Basic Process Science/Process Principles Critical Setup Parameters Failure Modes; Probable Cause/Solution Process - Specific Troubleshooting Guides and Technical Manuals Main Equipment Items and Function Detail pFMEA – Risks, Mitigations, Impacts 29 Key Take-aways from the Technology Transfer Guidelines • Standardize checklist for transferring product development, process development and analytical method development knowledge – Describes the key requirements that must be completed or addressed throughout the pharmaceutical development process • Requirements are summarized in key deliverables and reports such as: – Technology Transfer Strategy, Technology Transfer Checklist, Pharmaceutical Development Summary, Analytical Development Summary, Product Transfer Report, Pharmaceutical Development Report, Analytical Development Report • In developing a drug-device development model, must identify applicable requirements and integrate them into the development process – Product description to be updated to include inputs for active pharmaceutical agent – New pharma-specific requirements such as dose, route of administration, elution kinetics and metabolism of the drug substance 30 Thank you for your participation today Special Thanks to the following individuals: • Angela Falzone • Saurabh Palkar • Theresa Scheuble • Diana Dai • Dave Blazek • Rich Tennant If time allows, audience can share some of their bestpractices, experiences and lessons-learned Don’t forget to complete the evaluation forms ! 31
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