Académique Documents
Professionnel Documents
Culture Documents
Outline
Background
Case Study
1.
2.
3.
4.
Application Scenarios
CPV Benefit Estimates
Outstanding topics for further discussion
CPV Document Slide Pack V5.4
4-Feb-14
Background
The BioPhorum Operations Group (BPOG) is an industrywide collaboration to enable networking and to share best
practice in the area of Operations.
Beginning in 2008, it now has 26 member companies with
over 600 participating representatives. The community
primarily consists of experts from biopharmaceutical drug
substance operations, who meet and work together at
face-to-face meetings in the USA and Europe, on regular
teleconferences and via web meetings.
The group has established best practice on a wide range
of quality, engineering and organizational topics
considered central to the challenge of mastering effective
biotech drug substance operations.
CPV Document Slide Pack V5.4
4-Feb-14
Very few articles on the topic and most literature covers only
some aspects of the topic
Purpose
To exemplify implementation of Continued Process Verification
(CPV), third stage of process validation lifecycle as presented in
FDAs 2011 Process Validation guidance
To identify then realize the benefits of implementing CPV:
Comply with FDA guidance
Improve process control
Clarify opportunities for process improvement
Reduce operating costs
Reduce cost of goods
Increase access to products
Embedded
elements of an
illustrative CPV
plan
** Although A-mAb claims a design space, this case study does not address CPV
concepts associated with design space implementation
CPV Document Slide Pack V5.4
4-Feb-14
TPP
QTPP
CQA
CPP
PV Stage 1
Proven
Acceptable
Ranges
(Design
Space)
CPV
CPV
PPQ
EQ
PV Stage 2
Short-term
Plan
Long-term
plan
PV Stage 3
10
CPV Strategy:
Assurance of Control Strategy
Control strategy consists of quality-linked process parameters (CPPs and WCCPPs), Key Process Parameters (KPPs), Key Process Attributes (KPAs) and
IPCs.
Control strategy ensures required product quality (CQAs) and consistent /
robust process
Elements of control strategy should be monitored and improved in
accordance with ICH Q10 Sect. 3.2.i):
Pharmaceutical companies should plan and execute a system for the
monitoring of process performance and product quality to ensure a
state of control is maintained. An effective monitoring system
provides assurance of the continued capability of processes and
controls to meet product quality and to identify areas for continual
improvement.
CPV Document Slide Pack V5.4
4-Feb-14
11
CPV Strategy:
Production Monitoring Considerations
Demonstration of consistent robust production within validated
parameters
Product history and knowledge
Areas of greatest risk
Frequency of production
12
CPV Strategy:
Recommendations for A-mAb drug substance
Written plan to examine data that establishes process capability and control
limits that account for normal process variability
Assumes successful PQ (PPQ & EQ)
Not required to include every CQA, CPP, CMA, etc. in CPV plan, but provide
justification for what is included/not included
-- Explain why included items sufficient to meet CPV plans objectives
13
CPV Strategy:
Application to A-mAb Drug Substance Process
Example Step 6, Low pH treatment for reduction of adventitious viral agents (AVA)
Variable
Class
CQAs impacted
pH (during
inactivation)
CPP
AVA, aggregates
Post-inactivation
aggregates
CQA
--
CPP
AVA
Quantity of acid
added
KPP
--
Additional justification for including/excluding other variables (e.g., KPPs and KPAs, remaining CQAs
and CPPs) based on sufficient verification during PPQ and expectations of minimal variation
Qualitative nature of measurement may also justify exclusion
14
CPV Strategy:
Scope of Data Collection and Analysis Plans
Typically starts with the PPQ batches
Informed by clinical or scale up batch data
Two phases:
Initial, Short-term: Stage III-A
Prior to Statistical Process Control (SPC)
Accumulate ~30 batches to set limits based on statistical significance
Review parameters and update risks
15
CPV Strategy:
Establishing Initial Control Limits
Although clinical and scale up batches indicate process
performance, they may not give statistically valid basis for
establishing control limits. PPQ batches (commercial scale)
are of course relevant here
Initial control limits must not be regarded as acceptance criteria
16
17
18
Sampling Management
Sample plan and frequency
Routine monitoring
Non-routine monitoring
o Baseline monitoring, time-based periodic monitoring, or special event / change based
monitoring
Other sampling
o Intermediate stability/hold time, resin reuse, cleaning verification
19
Product variant
Truncated impurity
Antifoam
Methotrexate
Affinity ligand
DNA
Potency
product conc.
HCP
Aggregates
Charge Variants
Conductivity
10 mls
<-40 C
N
Y
42
Routine test
Retain
Non-Routine test
Stability
Reuse Lifetime Performance
Cleaning Verification
CPV Document Slide Pack V5.4
4-Feb-14
Endotoxon
U
n
it
o
p
s
Bioburden
Sample volume
Storage temp
Testing offsite
Testing onsite
Method SOP
pH
Retain
CQA/IPCs/KPAs
A280 conc
ROUT
RETN
NROU
STBL
LFTM
CLNV
Type of test
20
Sample location
Sampling device
Sample Collection
Sample Storage
Sample Transportation
Assay Testing
Results
Container MOC
Container Size
Sample Volume
Sample Replicates
Sample Retain
Sample Handling
Sample Labeling
Temp
Location
Transport
Who
Reference/Blank
Criteria
CQA
SEC
CPP
KPP
KPA
Routine Monitoring
Baseline Monitoring
Time-based Periodic
Monitoring
every X batches
2
Yes
aliquoted
in-line sensor
2-8 C
QC Lab
No
-20 C
Development lab
-70 C
Sample Control
QC Dept
Blank Solution
Control limit
Development Dept
Control
Control chart rules
External Lab
None
None
21
Data Management
Covers data collation, entry and verification
Data aggregation in usable format--preferably single digital file
Many data sources likely manually recorded
Error Proofing
Database
Errors during manual data entry are unavoidable but can be minimized
Data Storage System flags out of range /out of trend values
CPV Document Slide Pack V5.4
4-Feb-14
22
Description
Guidance text
Operational or
Performance
Elements
Multivariate
Analysis (MVA)
Column/Resin/UF
Membrane
Cleaning and
Performance
Lifetime
Verification
The extent to which some materials, such as column resins or molecular filtration media, can
be re-used without adversely affecting product quality can be assessed in relevant laboratory
studies. The usable lifetimes of such materials should be confirmed by an ongoing PPQ
protocol during commercial manufacture.
23
24
25
26
Small scale study completed from thaw through the production bioreactor to provide
additional process characterization data
o Outcome: Minor but statistically significant differences for key process parameter normal
operating ranges and attributes (e.g. VCC, , titer and turbidity at harvest) identified
evaluated to provide further verify step performance and process control ranges by examining data
before/after change. Based on this evaluation, and associated risk assessment, changes to CPV
monitoring plan can be considered.
27
28
CPV impact
For an initial period, in-process testing of Protein A content performed to assess process
capability
Newly identified CPPs monitored for a set of 3 batches, then consider addition to plan
CPV Document Slide Pack V5.4
4-Feb-14
29
Costs associated with CPV vary considerably based on data retrieval system
Estimate of effort required to create one CPV report for A-mAb product
For mostly manual system, working assumptions made:
o 3 CPV reports (excluding APR)
o 20 attributes/parameters trended
o Per data set: 3 hrs to retrieve; 1 hr to create control chart; 4 hrs to analyse / investigate
Indicates about 10 additional person-weeks of effort each year (~ $50 K at $200 K/person/year)
o For 3 sites each executing 5 CPV plans, manual implementation costs ~$250k/year
30
Return to initial short term control limits before setting (or re-setting) lifetime
long-term control limits after implementation of changes
Extent and application of statistics, especially for non-normal data
Use of formalized acceptance criteria or limits in an approved plan that might trigger
extensive investigations (eg, control chart rule triggers)
Decision-tree for product quality impact
31
BACKUP
32
Pfizer
This is an attempt to link CPV related documents (red) with corporate (orange)
and site specific (white) documentation. It is still a work in progress.
CPV Document Slide Pack V5.4
4-Feb-14
33
Industry Case Study: Continued process verification (CPV) for a biotech product
Beth Junker, Merck and Co, on behalf of BPOG
Version: 1
Date: 21 Dec 2013
Continued Process Verification (CPV) encompasses a written plan for monitoring a licensed
biopharmaceutical manufacturing process, then documenting and reporting the results. CPV reporting
provides a basis from which to improve process understanding, and hence risk assessment, control
strategy, and ultimately process improvement. This presentation describes one of the first cross-company
efforts to be compiled on CPV in response to the FDAs 2011 process validation guidance. It has been
created by representatives from 20+ biopharmaceutical companies, sharing and building knowledge, with
support and facilitation from the BioPhorum Operations Group (BPOG) (www.biophorum.com). We
describe general approaches to implementing CPV and offer some specific recommendations on the
content of a CPV Protocol, along with associated rationale. These recommendations are based on a typical
cell culture production process for making a fictitious monoclonal antibody product described in the A-Mab
Case Study. Consequently, these recommendations may not apply directly to specific products or
processes, but the principles and concepts described can be considered where applicable.
In general, the nature and extent of CPV is aligned with the outcomes of Process Qualification (PQ).
Adopting a monitoring system to reveal manufacturing trends offers the ability to acquire more data over
the products lifetime. Hence, a deeper understanding of the process is acquired, along with a foundation
for enhancements to the Control Strategy (CS). CPV execution may involve examination of process control
variables to improve methods for data tracking and analysis. Monitoring process performance provides the
opportunity to identify sources of variation and hence improve process robustness. For products that are
recently commercialized, there is unlikely to be a statistically robust set of manufacturing scale data. To
practically, manage this situation, short term control criteria are set initially based on prior process
experience including at the laboratory or clinical scales. This early period of production then is used to
establish the longer term criteria.
The implementation of CPV systems likely requires significant effort, beyond what is typically prepared for
the Annual Product Review (APR), because substantial amounts of additional data are collected and
analyzed to improve understanding of process variability. The benefits of improved process management
are expected to outweigh this additional investment. Such benefits include improved information
supporting both annual products and continuous process improvements. The frequency of data analysis
and reporting depends on several factors, including: whether production is campaigned or continuous; the
extent of variability apparent in the process; if risks to product quality (and thus product disposition) and
process consistency are sufficiently mitigated, and the intended usage of the reported data.
CPV Document Slide Pack V5.4
4-Feb-14
34
35
Afucosylation
2-13%
Aggregation
0-5%
Deamidated isoforms
NA
Galactose Content
10-40%
HCP
0-100 ng/mg
Sialic Acid
High Mannose
0-2%
3-10%
100 ng/mg upper limit claimed based on prior clinical experience with XMab.
In vitro studies with A-Mab.
Clinical Experience with A-Mab.
Non-Glycosylated
Heavy Chain
0-3%
36
37
CPP
KPP
none
temperature, time
Step 1: Culture
expansion in
disposables
none
Step 2: Culture
expansion in
fixed bioreactors
none
none
Step 3:
Production
culture
Step 4:
Centrifugation
and filtration
38
CPP
KPP
Step 5: Protein A
Chromatography
end collection
Step 6: Low pH
treatment
none
Step 7: Cation
Exchange
Chromatography
none
Step 8: Anion
Exchange
Chromatography
none
Step 9: Small
virus retentive
filtration
none
Step 10:
Ultrafiltration,
diafiltration
none
none
none
none
39
Upstream
Process:
Starting Material:
Seed
Maintenance
Seed
Maintenance
Nutrient
Feeds
Process Flow charts used as basis for CQA/CPP evaluation
and establishment of Control strategy prior to Product &
Process Qualification (PPQ)
Production Bioreaction
(15,000L)
Harvest Centrifugation and
Filtration
40
Downstream
Process:
Starting Material:
- Clarified Bulk
Low pH Incubation
Cation Exchange
Chromatography
Anion Exchange
Chromatography
42
43