Académique Documents
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Manufacturing Processes
1
Agenda
• Introduction
• Use of prior knowledge to support effective process
design
• PPQ Lot Tool: Determining the number of lots in PPQ
• Use of CPV to continuously improve the commercial
Control Strategy
• Closing Remarks
2
Introduction
Stage 3
Stage 1 Stage 2
PPQ
Continued Process Verification
Process Design
(CPV)
Prior
3 Knowledge
What is the Value of Validation Runs?
• They tell you if you can run your commercial process under
well controlled, center point oriented operating parameters
and reproducibly produce quality product for three – five runs
and make product that meets the required product quality
(specification).
Characterization Design Space
Process Validation
Acceptance Criteria
Action Limits
Operating
Limits
Commercialization
FIH Process Comm. Process Process Conf. & PAI & Launch Post-approval
Process Development Development Char. File prep Prep Development
Tool - Continuous
Prior Knowledge PPQ Size improvement of the
control strategy via
(product specific and
APR
platform knowledge)
Use of prior knowledge to support
effective process design
Stage 3
Stage 1 Stage 2
PPQ
Continued Process Verification
Process Design
(CPV)
Prior
Knowledge
The PPQ Paradigm Requires New
Approaches to Process Design
• Enhanced approaches provide the overall framework:
– Assessment of product attribute criticality
– Development of risk and knowledge based integrated control
strategy
10
PPQ Lot Tool: Determining the Number of
Lots in PPQ
Tool -
PPQ Size
Process Validation Guidance:
Necessity for Justification of Number of PPQ Lots
PPQ Lot Tool provides an assessment of factors that may have impact
on product/process understanding
• Quantify the amount of Stage 1 process design information
• Quantify the quality of the Stage 1 process design information
• Incorporate indirect measures of performance
• Adjust the PPQ size based on the amount and quality of process
design information
or
• Assess for gaps in Stage 1 knowledge
Result: Data / risk driven and structured approach to a PPQ strategy vs.
one size fits all strategy
Goal: Leverage information from Stage 1 using
a decision making tool to inform size of PPQ
A final score is generated from the tool which describes the knowledge at
the time of PPQ Score is translated into a lot count guidance
14
Snapshot of PPQ Lot Tool scoring—Example
Performance Factor Status Scoring Weight
Characteristic (True/False) (Fixed: 0 to 9)
Product/Process Product Quality Risk True 0 False =5
Assessment is complete and
high risk items have been
mitigated
DP only: Experience with False 3 False=3
multiple DS ages
Process Characterization is True 0 False=7
complete
Raw Materials Experience exists for True 0 False=7
multiple lots for complex raw
materials per supplier
Facility Receiving plant has a True 0 False=3
successful inspection history
(3/25)100%=
SCORE
12%
Compute the weighted mean and convert to a %
15
PPQ Lot Tool: Action threshold table
# of Lots for
Score (%) Justification
PPQ
Recognition of limited process understanding and
> 70% 6 to 8
experience (e.g., novel technology)
Recognition of moderate process understanding
> 30% to ≤ 70% 3 to 5
and experience
Recognition of a well understood process and
≤ 30% 1 to 2
significant experience
Example score: 12% would require 1 to 2 lots for the PPQ campaign
16
Use of CPV to Continuously
Improve the Commercial Control
Strategy
Continuous
improvement of the
control strategy via
APR
CPV leverages existing Quality Management
Systems • Specifications
• IPCs
• CAPA • Stability Protocols
Trends, low capabilities and • Change Control • Analytical Methods
excursions to controls are • MPs & SOPs
investigated and corrective • Valdn Protocols
actions taken to ensure processes
remain in a state of control
Improve Plan
Comprehensive
Ensure
Annual
Quality
• Manufacturing
Monthly Data
• Analytical Testing
Review
Programs that directly
monitor mfg process • Process Monitoring (IPCs)
Program-specific
• Complaint trending
Programs that indirectly
monitor mfg process • NC trending
performance • Stability trending
CPV activities are performed today, but we are developing tools and integrating
processes to make the improvement cycle more efficient, timely and robust
Transition from Stage 2 to Stage 3
• CPV procedurally begins with the first lots produced
after the PPQ campaign
• Use Stage 1 / 2 data to establish variability estimates as
early as possible
– Representative clinical, engineering and PPQ data may be used in
control limit and capability calculations
Any
Execute the
No parameter
Annual Product
requires
Review (APR)
evaluation?
Yes
Significant
Process Change
APR APR APR APR
PPQ PPQ
PPQ sampling baseline
30 lots 30 lots
Change opportunity is with non-
critical parameters
Baseline monitoring to
maintain control
Monitoring levels may step down when Monitoring levels may step up when we need to
the process is stable and capable monitor more for understanding and control
Note: Magnitude of the changes to the monitoring plan are not to scale; they are for illustration purposes only
Approaches to Stage 3
• Filed (or regulatory commitments) CPV parameters (i.e., in-process
controls, specifications) provide assurance of consistent product quality
• Additional enhanced process monitoring (i.e., non-critical parameters,
multivariate statistical models) is extremely useful for:
– Identifying subtle causes of variation
– Identifying improvement opportunities
– Troubleshooting process performance
– Increasing at scale process knowledge, etc.
• To be fully realized, enhanced monitoring needs to be treated as a
continuation of Stage 1 process design, i.e.:
– Flexibility to timely add and subtract parameters, revise limits, perform complex
analyses, avoid non-value added numerical limits without prior regulatory
approval (these could be confirmed by agencies upon inspection)
– Parameters identified thorough enhanced monitoring as critical would be added
to licensed CPV program
Closing Remarks
• Process Performance Qualification concepts , stage 1-
3, should be built into our process validation systems
• The proposed approaches represent a standardized
approach to inform PPQ plans and CPV
• Additional pre-filing discussions with Agencies are
warranted regarding:
o Effective implementation these process validation tools
o Information to be submitted in license applications to facilitate
the Agency’s review
o Changes to be handled by the organizations Quality
Management System (QMS)