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CVM GFI #126 BACPAC I-Intermediates in Drug Substance Synthesis Bulk Actives Postapproval Changes: Chemistry, Manufacturing, and Controls Documentation

FinalCenter for Veterinary Medicine06/01/2006

Description

Under section 506A of the Federal Food, Drug, and Cosmetic Act (the Act), the holder of an NADA or ANADA must notify FDA about each change in each condition established in an approved application beyond the variations already provided for in the application. The Act provides for four reporting categories: (1) Prior Approval Supplement, (2) Supplement – Changes Being Effected in 30 days, (3) Supplement – Changes Being Effected, and (4) Annual Report. The reporting category for a change is based on the potential for the change to have an adverse effect on the identity, strength, quality, purity, or potency of the drug product as these factors may relate to the safety or effectiveness of the drug product. This guidance provides recommendations on reporting categories for postapproval changes relating to intermediates in drug substance synthesis based on a determination by the Center for Veterinary Medicine (CVM) of the potential for a specified change to have an adverse effect on the drug product. It also provides recommendations on the information that should be provided to CVM to ensure continued drug substance quality and drug product quality and performance characteristics.

Scope & Applicability

Product Classes

4
Animal Drug

Drugs subject to section 512 of the FD&C Act

Synthetic peptides

Product type excluded from the scope of this guidance

Drug Substance

RTRT and CTD sections apply to drug substances

Drug Product

RTRT and CTD sections apply to drug products

Stakeholders

4
Applicant

Entity submitting development data and knowledge; Entity performing the work process for change

Supplier

Facility supplying raw materials or ingredients; Facility providing raw materials to a manufacturer

DMF Holder

Entity that owns and maintains a Drug Master File

Master File Holder

Entity responsible for maintaining the DMF

Regulatory Context

Attributes

8
Scale of manufacture

The size of the batch or production run

Total Impurities

The sum of all impurities observed.

Batch

Specific quantity of a drug intended to have uniform character and quality

Physical Properties

Equivalence of physical properties; Evaluation of physical properties for drug substance; Properties likely to influence drug product manufacturability; Attributes such as physical state, melting point, solubility, and density.

Impurity Profile

levels of existing and new impurities; Characteristic of drug substance that may change with starting material redesignation; A comparison of the impurity profile of pre- and post-modification material to establish equivalence; Evaluation of the impurity profile for intermediates or drug substance; Potential to adversely affect drug substance quality; A description of the identified and unidentified impurities present in a drug substance.; The description of identified and unidentified impuritie

Morphic Form

Physical property considered critical for evaluation of equivalence

Particle Size

Characteristic relevant to nanotechnology NDIs

Batch Size

The amount of product held or processed at a specific step.; Used to calculate servings per batch

Identified Hazards

Hazards

2
Adventitious agent

Potential that transformation was caused by an adventitious agent; A microorganism inadvertently introduced into the production of a biological product.; Detection of contaminants in cell substrates and vaccine components

Impurity

New process impurities generated by manufacturing changes

Related CFR Sections (3)

See Also (8)