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Quality Issues For Clinical Trial Materials PowerPoint Presentation

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Description : Check out this medical PowerPoint presentation titled "Quality Issues for Clinical Trial Materials: The Chemistry, Manufacturing and Controls (CMC) Review" by Dorota Matecka, PhD.

This medical PowerPoint presentation is about the quality issues for clinical trial materials. Clinical trial materials are products that are used in clinical trials to evaluate their safety and effectiveness. The Chemistry, Manufacturing and Controls (CMC) review is an essential component of the regulatory process for clinical trial materials, as it ensures that the materials are of high quality, and meet the appropriate regulatory standards. The CMC review process is a comprehensive evaluation of the manufacturing process, quality control, and stability of the clinical trial materials.

The following are some of the quality issues that the CMC review process typically focuses on:

Manufacturing process: The manufacturing process for the clinical trial materials must be well-defined, controlled, and reproducible. The process must be thoroughly documented, and the materials must be manufactured according to Good Manufacturing Practice (GMP) guidelines.
Characterization: The clinical trial materials must be fully characterized, and their physical and chemical properties must be well-understood. The analytical methods used to characterize the materials must be validated and reliable.
Impurities: The presence of impurities, including residual solvents, residual catalysts, and other contaminants, must be minimized and controlled.
Stability: The stability of the clinical trial materials must be well-established. The materials must be able to maintain their identity, strength, and purity throughout their shelf life.
Container-closure system: The container-closure system for the clinical trial materials must be appropriate and compatible with the materials. The container and closure must be able to protect the materials from contamination and degradation.
Batch-to-batch consistency: The clinical trial materials must be manufactured consistently from batch to batch. The manufacturing process must be robust and reliable, and any changes to the process must be well-controlled and documented.

In summary, the CMC review process plays a critical role in ensuring the quality of clinical trial materials. It is essential that manufacturers of clinical trial materials understand the regulatory requirements and guidelines related to CMC, and work closely with regulatory authorities to ensure that their products meet the appropriate standards.

Tags : clinical trial materials, Chemistry, Manufacturing and Controls (CMC) review, pharmaceuticals, pharmaceuticals PowerPoint presentations

Published on : Jun 23, 2023 | Views : 785 | Downloads : 2

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Slide 1-

Quality Issues for Clinical Trial Materials: The Chemistry, Manufacturing and Controls (CMC) Review Dorota Matecka, Ph.D. Office of Pharmaceutical Quality (OPQ), CDER
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Outline Pharmaceutical Quality CMC Requirements for INDs CMC Safety Concerns Impurities and Specifications Other CMC Considerations IND Guidance Sources Summary
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What is Pharmaceutical Quality? The suitability of either a drug substance or drug product for its intended use. This term includes such attributes as the identity, strength and purity(ICH Q6A) The degree to which a set of inherent properties of a product, system or process fulfills requirements (ICH Q9) Patient & Product Product & Process
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5 Pharmaceutical Quality The challenge for the Quality review and inspection for a New Drug Application is to assure that the characteristics and performance of the clinical batches will be replicated consistently in the commercial batches
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Drug Substance and Drug Product Drug Substance (Active Pharmaceutical Ingredient, API) An active ingredient, intended for incorporation into a finished dosage form, that meets the statutory definition of a drug (i.e., that is intended to furnish pharmacological activity or other direct effect in the diagnosis, cure, mitigation, treatment, or prevention of disease or to affect the structure or any function of the human body) Drug Product A finished dosage form (e.g., tablet, capsule, or solution) that contains a drug substance, generally but not necessarily in association with one or more other ingredients 21 CFR 314.3 Definitions
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Investigator Brochure CMC 21 CFR 312.23(a)(5) Investigator’s brochure If required under § 312.55, a copy of the investigator’s brochure, containing the following information: A brief description of the drug substance and the formulation, including the structural formula, if known.
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IND Regulation 21 CFR 312.23(a)(7)(i) As appropriate for the particular investigations covered by the IND, a section describing the composition, manufacture, and control of the drug substance and the drug product............... ........... sufficient CMC information to assure the proper identification, quality, purity and strength of the investigational drug
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Identity The structure of the Drug Substance (API) must be proven and controls must be used in the manufacturing process to ensure that the same structure is obtained in every batch The types of techniques or combination of techniques that may be required to fully elucidate the structure depends on the nature of the drug substance
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Strength (Potency/Assay)* * The drug product needs to contain the required amount of drug substance Assay of the Drug Substance Validated stability-indicating assay or bioassay Assay of the Drug Product Validated stability-indicating assay or bioassay (assay needs to be selective for the drug substance without interference from excipients, impurities, or degradants) Well-controlled manufacturing processes In-Process Blend Uniformity Uniformity of Dosage Units Container Closure System Stability (Expiration Dating Period)
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Purity Chemical purity (process impurities, degradation products, leachables from container closure system, etc.) Microbiological purity (microbial limits; absence of specific microorganisms, etc.)
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CMC Regulatory Requirements [21 CFR 312.23(a)(7)] Regulations emphasize the graded nature of CMC information needed as drug development progresses under an IND The amount of information needed depends on: Phase of investigation Dosage form Duration of study Patient population Amount of information otherwise available The emphasis in an initial Phase 1 CMC submission should generally be placed on providing information that will allow evaluation of the safety of subjects in the proposed study
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Drug Substance Requirements for INDs Description and characterization Manufacturer (name, address, contact information) General method of preparation/synthesis Specification (tests, analytical procedures and acceptance criteria) Batch analysis data for clinical trial batch Stability (through end of clinical trial)
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Drug Product Requirements for INDs Components Novel excipients may require additional information Quantitative composition Manufacturer (name and address) Description of manufacturing and packaging process Container/closure system Specification (tests, analytical procedures and acceptance criteria) Stability (through end of clinical trial)
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Other CMC Information Labels and labeling – mock-up labels Caution statement that reads: “Caution: New Drug Limited by Federal (or United States) law to investigational use.” Environmental Assessment Claim for a categorical exclusion Placebo information
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CMC Safety Concerns(potential “hold” issues) Product made with unknown or impure components Chemical structures of known or likely toxicity Impurity profile is insufficiently defined or indicates a risk or exceeds levels qualified through toxicology studies Lack of sterility assurance or endotoxin control (e.g., injectable drug products)
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CMC Safety Concerns(potential “hold” issues) cont’d. Synthesis/manufacturing information provided is insufficient to evaluate the compound claimed is actually manufactured Poor or unknown manufacturing procedures, including compounding Product strength is insufficiently defined Product not stable through clinical study duration Poorly characterized master or working cell bank
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What is an impurity? Any component of the new drug substance that is not the chemical entity defined as the new drug substance (ICH Q3A) Any component of the drug product that is not the drug substance or an excipient in the drug product (ICH Q3B)
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Impurities Drug substance impurities Organic impurities (process- and drug related, e.g., starting materials, by-products, intermediates, degradation products, reagents, catalysts) Inorganic impurities (heavy metals or other residual metals, inorganic salts) Residual solvents, polymorphic forms, enantiomeric impurities, extraneous contaminants Drug product impurities Degradation products of the drug substance Reaction products of the drug substance with excipients and/or with immediate container/ closure system
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Impurities More Toxic than Drug Desmethylprodinean opioid analgesic
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21 Impurities Generally limits are based on levels qualified in non-clinical testing DS and DP specifications should include impurity test and acceptance criteria for Individually specified for recurring impurities (if above the identification threshold) General threshold limit for those impurities not individually specified Total impurities Special considerations for potential or known genotoxic impurities
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Specification Defined in ICH Q6A as: “…a list of tests, references to analytical procedures, and appropriate acceptance criteria, which are numerical limits, ranges, or other criteria for the tests described. It establishes the set of criteria to which a drug substance or drug product should conform to be considered acceptable for its intended use Universal tests described in ICH Q6A for: Drug substance Drug product Includes attributes that serve as surrogates for performance
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Drug Product Specification
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Drug Substance Specification
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CMC Efficacy Concerns Generally not a reason for a “clinical hold” Assay uncertainty Uniformity of content Bioavailability
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Rifampin Bioavailability R. Cavenaghi, Bull Int Union Tuberc Lung Dis 1989 Mar; 64(1):36-7 Particle size Formulation/manufacture Standard product Standard product Process change Excipient change Same process Excipient change Process change
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Use of Foreign Comparators in Clinical Trials* Sample comment: “The use of FDA-approved drug products provides assurance of drug quality. Where this is not possible and local products are used, documentation should be provided to show that the drug product is comparable in quality to the US product. Depending on the drug product, this could involve, for example, comparing impurity and dissolution profiles, and content uniformity.” * Pre-IND approach recommended
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Excipients – Quality Considerations Suitability for intended use (target organ/tissue) Functionality Compatibility with drug substance Safety/performance issues Source (USP/NF; FDA Inactive Ingredients Database) Excipients of Human or Animal Origins Novel (new) Excipients* *(1) Guidance for Industry: Nonclinical Studies for the Safety Evaluation of Pharmaceutical Excipients; (2) USP General Chapter <1074>
Slide 29-

Container Closure System The sum of packaging components that together contain, protect, and deliver the dosage form (primary and secondary packaging components) - IND should include a brief description of: The packaging components The assembled packaging system Any precautions needed to ensure the protection and preservation of the drug substance and the drug product during the use in the clinical trials
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Container Closure System - Quality Considerations Water / Moisture / Humidity Light Oxygen Temperature Contaminants in primary packaging component Leachables (primary or secondary component) Loss of solvent / leak in packaging system Microbial contamination Sterility assurance
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Stability 21 CFR 312.23(a)(7)(ii): …stability data are required in all phases of the IND to demonstrate that the drug substance and drug product are within acceptable chemical and physical limits for the planned duration of the proposed clinical investigation The amount of data will depend upon the duration of the proposed clinical study
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Use of Stability Data To support investigational studies To ensure that the quality and safety of the investigational product is maintained throughout the clinical trial period To obtain impurity profile of the batches used during non-clinical toxicological studies
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Expiration Dating Period Expiration dating period is not required for the investigational materials Reconstituted products are required to have a “use by” date CFR 211.137 (g). ---”where new drug products for investigational use are to be reconstituted at the time of dispensing, their labeling shall bear expiration information for the reconstituted drug product”
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Clinical Trial Supplies* Examine container integrity on receipt Confirm label’s 21 CFR 312.6 compliance Store at recommended conditions Document: Receipt and storage Condition of product on receipt Dosing (including e.g. date & time, lot#, etc) Reconciliation of all product at study conclusion Records kept on-site *See International Conference on Harmonisation of Technical Requirements for Registration Of Pharmaceuticals for Human Use Guidance E6, “Guideline for Good Clinical Practice” http://bit.ly/E6-GCPs and 21 CFR 312.62
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IND Guidance Sources Food Drug and Cosmetic Act Code of Federal Regulations (Title 21) 21 CFR 312 (IND content and format) 21 CFR 210 and 211 (CGMP) Guidance FDA ICH
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FDA IND Guidance Phase 1 (http://bit.ly/IND-Phase-1) Phase 2 & 3 (http://bit.ly/IND-Phase2-3) Meetings (http://bit.ly/IND-meetings) MaPP 6030.1 (http://bit.ly/IND-MaPP) Exploratory IND (http://bit.ly/Expl-IND) GMP for Phase 1 (http://bit.ly/IND-cGMP)
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Guidance for Industry: CGMP for Phase 1 Investigational Drugs (2008) Frequent questions about GMP expectations for Phase 1 trial materials; clear need for guidance Developed by Agency workgroup (CDER, CBER, ORA) composed of compliance staff, CMC reviewers, and investigators FDA’s desire to ensure appropriate quality for early clinical trial material, without impeding drug development Articulates FDA’s intent to implement an incremental approach to CGMP compliance for clinical investigational products FDA Guidance issued in 1991 “Preparation of Investigational New Drug Products (Human and Animal)” (reprinted November 1992) still applies to Phase 2 and Phase 3 clinical trial materials
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Meetings Pre-IND Meetings EOP2 Meetings Ensure that meaningful and adequate data are generated during Phase 3 studies Identify safety issues, scientific issues and/or potential problems and address/resolve them prior to initiating Phase 3 studies Identify potential roadblocks that could affect review of marketing application Discuss and agree on plans/protocols relative to: Regulations, guidances, and FDA policy Quality by Design (QbD) approaches, if used Pre-NDA Meetings Generally focusing on filing and format issues at least 6 months prior to NDA submission Discussion of any problems that can lead to refuse-to-file recommendation or hinder the review process
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Summary Sufficient CMC information should be provided in an IND to assure identity, quality, purity and strength of the study drug The level of CMC information increases as development progresses Critical CMC safety issues (including impurities) should be identified - safety concern is the primary reason for placing an IND on clinical hold based on CMC section Other quality issues should be considered and evaluated for INDs CGMP should be applied - Phase 1 drugs do not need full CGMP but do need good manufacturing controls Recommendations of ICH/FDA guidances and input from FDA are helpful during drug development
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Thank you!
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