Process validation
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Talk points
Objectives of review of quality data- reminder
Process validation, definition and current approaches
Risk assessment as part of process validation
Validation scheme: Monitoring and Sampling
Specific topics: Blend uniformity and validation of compression step
Process validation commitment
Retrospective validation
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Reminder
Objectives of assessment of quality part
To provide the highest assurance that all production batches (unit
doses) will be consistently efficacious as the clinical batch(es)
To reduce risk to safety via the highest assurance of acceptable and
consistent quality of the product and its components
Process
validation
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Process validation
The collection and evaluation of data, from the process
design stage through commercial production, which establishes
scientific evidence that a process is capable of consistently
delivering quality products. (FDA)
Documented evidence which provides a high degree of
assurance that a specific process will consistently result in a
product that meets predetermined specifications and quality
characteristics. (WHO)
The documented evidence that the process, operated
within established parameters, can perform effectively and
reproducibly to produce a medicinal product meeting its
predetermined specifications and quality attributes.(EMA)
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Process validation
Traditional vs. new paradigm
ICH Q8,
Development- QbD
Enhanced-
Basic Development and
process
qualification
Pilot batch
Post manufacturing
approval
changes/ch
ange Continuous and
controls/risk extensive monitoring Control
analysis Process of CQAs and CPPs Strategy
validation- 3 for each production
batches batch
ICH Q9
and Q10
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FDA, January 2011
Latest guidelines
WHO, Revised Annex 7 of
WHO GMP guide (draft for
EMA, February 2014
comment)
Continuous process verification Continuous process verification Alternative approaches:
(CPV) (CPV) -Traditional approach
-Continuous process
verification
-Hybrid approach
Process design and Initial Process design and initial CPV protocol to be supported
validation (process validation (initial process by extensive development
qualification- PPQ) are initial verification) are initial phases of information and lab or pilot
phases of CPV CPV scale data. Executed on each
production batch
No mention of number of Mentions data on at least three Number of batches specified for
batches for initial process pilot or production batches traditional approach
performance collected as part of process - minimum of three production
qualification/validation (rather design batches unless other wise
must be justified based on justified.
overall product and process
understanding)
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Types of process validation
Prospective validation Concurrent validation Retrospective validation
Protocol reviewed and Protocol reviewed and Protocol does not need to be
accepted, Product PQD; OR accepted, Product PQD submitted
Protocol executed before
submission or PQ
Execute and finalize process Execute and finalize process Prepare product quality
validation on the first three validation on the first three review report on already
production batches production batches manufactured production
batches
Commercial batches to be Each validation batch can be Applicable for submissions
released only after validated and released. meeting criteria for
satisfactorily conclusion of Applicable for low demand established products as
process validation on three products (such as NTDs, described in Annex 4, TRS
batches orphan drugs or other 970
seasonal products)
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Process validation- Role of assessment
Design Operational Performance Process
qualification qualification qualification validation
Dossier
GMP
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Process validation phases Includes
demonstration of
content uniformity of
the clinical batch
Pre-validation
phase
Protocol Information
Preparation from
primary/clinical
manufacturing
(scale up Process risk
information) assessment
information
Validation phase (identification
Protocol execution Information from of critical
product steps)
development
studies
Post valdn phase: (identification of
Review of process, critical attributes)
deviations, failures,
need for
improvement,
9 scale up etc…
Risk assessment
Part of process development and protocol preparation
Risk matrix- usually as part of process development
• Critical quality attributes (CQA) vs processing stages, e.g. dissolution vs
granulation
• CQA vs critical process parameters, e.g., dissolution vs kneading time
Failure mode analysis- usually as part of process validation
To identify critical attributes, processes and parameters
Informed validation
To establish control strategy
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Process steps to be validated
All steps that are generally considered critical (medium and
high risk steps) should be monitored/scrutinized
by summarizing actual process parameters applied and observations
recorded
• e.g. sifting stage, wet and dry granulation stages
observations serve as feedback for future refinement of process
parameters
In addition, where feasible, sampling and testing should be
performed
• e.g. drying, mixing steps, compression, filling
• results measure effectiveness and consistency of the immediate as well
as preceding steps- e.g. final blend characteristics are mainly shaped by
wet/dry granulation process
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Validation scheme- example
Processing steps Critical parameters Validation scheme
Dispensing Weight checks Monitored
Sifting Mesh size Monitored
Wet Granulation and drying Amount and addition rate of Monitored, Drying uniformity to
granulating agent, mixing speed, be tested
time, as well as sequence of
events
Dry Granulation Slugging /compaction Monitored only or Monitored and
parameters sampled?
Blending mixing speed, time Monitored; Blend uniformity to be
established
Lubrication mixing speed, time Monitored; Blend uniformity from
mixer and bulk container
Compression Initial set up parameters, Monitored; Several samples to
speed, applied pressure, be sampled and tested for IPQC
12 parameters
Monitoring- Example:
Compaction
BMR Set Batch 1 Batch 2 Batch 3
parameters
e.g. of Cycle 1 Cycle 2 Cycle 1 Cycle 2 Cycle 1 Cycle 2
parameter
s
Roller 8-15 10 10 10 10 10 10
speed
(RPM)
Roller 40-60 41-42 42-43 41-43 41-42 41-42 41-43
pressure
(Bars)
Vertical 50-100 75 75 75 75 75 75
feed screw
(RPM)
Any comment vis à vis the difference between BMR set range and actual
applied inputs?
Horizontal 10-20 15 15 15 15 15 15
feed screw
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(RPM)
Example: Monitoring and sampling:
Drying
Monitoring Set parameter Observation
Batch X Batch Y Batch Z
Inlet temperature 60+/-10oC 62-65 52-63 52-60
Outlet temp 29-44 31-47 28-36
Total drying time 65 65 80
(min) (for
information)
Sampling and Spec Batch X Batch Y Batch Z
testing
Location 1 0.75-2.25% 1.54 1.53 1.70
Location 2 1.94 2.01 1.80
Location 3 2.03 1.30 2.05
Location 4 1.89 1.87 2.20
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Blend uniformity- Sampling
location and method
Sampling location -usually predetermined as part of qualification
of the mixer (i.e. mostly GMP issue)
But, in the dossier, we at least check if periphery, center positions and
various other positions are considered
Samples from each location are usually taken in triplicate
Samples should also be taken from the blend container- to
evaluate impact of transfer
important for low dose products and particularly for DC processed blend
Sampling should be done consistently and in away that does not
disturb the bulk blend state – such aspects (e.g. type of sampling
thief used) are better addressed at the time of inspection
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Blend uniformity- Sample size
What is an acceptable amount for samples taken at each location?
C. Morten, PIAT programme, University of Manchester
Normally 1-3 time of the FPP unit dose weight
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Sampling and testing plan- Lubrication- example
Sample Sample size Sample Tests Acceptance
location analysed limits
Lubrication 10 position 850-2550mg 10 Individual Blend Mean: 95.0-
from in triplicate samples uniformity 105.0%,
Octagonal individual:
blender and 90-110%,
blend RSD: NMT
container 5%
Do you agree
What Samples
are the 50gmwith Composite missing
Complete As per blend
minimum tests
fromwetop, samples parameter?
analysis as spec
expect tomiddle
the acceptance
see in and
criteria? per routine
?blend spec
bottom blend spec
?Acceptable
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Compression – Sampling frequency and size
depends on the length of the run time/
batch size
we expect frequent sampling than the normal IPQC
frequency
the number of samples taken should be greater
than those taken during a normal IPQC sampling
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Extensive sampling- example
(there are several other approaches)
IPQC testing schedule Normal production batch Validation batches
Group weight and
appearance, every 30
minutes; others every 1 hour About 300 tablets
(at least 3 times)
All in process parameters at -
start, middle and end of
(different hopper fill levels)
Additional samples at high, -
low speed; at high and low
hardness levels
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How to demonstrate consistency?
3
sigma
process e.g. 4 sigma
process
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Process validation- material type
Validation focuses on
mixing time and conditions to clear solution, if deemed
relevant
• bulk liquids: pH, specific gravity, clarity of solutions;
assay
filling process
• filled units:- Volume/Wt variation.
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Process Validation- material type
Focuses on
homogenization
filling
• Viscosity, fill volume/weight variation,
• Other critical attribute that may be affected by filling process?
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Matrixing/bracketing approach
Multiple strengths of same product (common
blend)
until stages of final blend: 3 consecutive batches of the
common blend (instead of 3 separate blend batches for each
strength)
compression: 3 consecutive batches of each strength
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Review of protocol- main aspects to check
Scope of the validation (type, batch size, reason)- do they reflect the
planned validation? Highest batch size to be validated?
Major equipments identified (in line with BMR) and a provision for
recording their Q status included?
Reference to current master production record included?
Summary of critical steps identified? is this convincing ?
Monitoring and sampling plan provided?- Do you agree with the steps
monitored/sampled?
Sampling schedule, schematics, tests and acceptance criteria, as well
as current specification codes included ? Are these acceptable?
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Review of validation report
Is the reported data relevant for the proposed manufacturing
process and scale
equipment used, process parameters applied
All critical steps adequately monitored/sampled?
Level of sampling and size are acceptable?
All results within acceptable limits? Particular trend?
Deviations appropriately evaluated and discussed?
Is the overall process in sufficient control? Is there any thing that
should be improved or refined for future production batches
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Thank you,
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