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Q12 Technical and Regulatory Considerations for Pharmaceutical Product Lifecycle Management Annex

FinalCenter for Drug Evaluation and Research Center for Biologics Evaluation and Research05/11/2021
Established ConditionsChange control systemPharmaceutical Quality SystemProcess ValidationQuality Risk ManagementGMPsCQACPPControl StrategyDesign SpaceCritical Quality Attribute

Description

The examples provided in sections I.A through I.F of the ICH Q12 Annexes are mock examples provided for illustrative purposes. They only suggest how the tools described in sections III, IV, and V of the ICH Q12 guidance could be applied, and should not be used as a template or the sole basis for a regulatory submission. In addition, the reporting categories, as described in section II of the ICH Q12 guidance, may differ across regions depending on regional legislation; the nature of the product; and the Marketing Authorization Holder’s (MAH’s) demonstrated understanding of the product, process, and analytical procedure.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

3
Chemical Medicinal Product

Identification of Established Conditions for the Manufacturing Process; Annex IA focuses on chemical medicinal products

Small Molecule Drug Substance

Subject of the PACMP example

Biological Medicinal Product

Identification of Established Conditions for the Manufacturing Process; Annex IB focuses on monoclonal antibody example

Stakeholders

3
Marketing Authorization Holder

Entity responsible for managing the submission of PBRERs

Contract Manufacturing Organizations

Facility fee requirements for CMOs; CMOs qualifying for reduced facility fees

MAH

Marketing Authorization Holder responsible for safety reporting; Marketing Authorization Holder responsible for providing exposure data; Marketing Authorization Holder responsible for signal evaluation and reporting.; Marketing Authorization Holder responsible for presenting efficacy information

Regulatory Context

Regulatory Activities

5
PACMP

Post-Approval Change Management Protocol examples; Postapproval Change Management Protocol; Post-Approval Change Management Protocol for site transfers and process changes

Regulatory inspection

Inspection by authorities requiring access to source records.; Access to source records for assessment of trial conduct

Post-implementation notification

changes can be made with immediate or other notification to regulatory authorities

Marketing application submissions

ICH guidelines standardized safety reporting and marketing application submissions

Marketing Authorization Applications

Applications consisting of combinations of development approaches

Document Types

3
Product Lifecycle Management Document

Document outlining ECs and reporting categories; PLCM document included in eCTD section 3.2.R; Document including proposed ECs and reporting categories; Appendix C example of a PLM document

Analytical validation protocol

prospective protocol should be prepared and approved internally

Common Technical Document

Format for submitting development information; Module 3 of the CTD for detailed descriptions of analytical procedures; ICH guideline M4Q(R1) for the registration of pharmaceuticals.

Attributes

10
Feedstock pH

Input parameter for anion exchange chromatography

Accuracy

Performance characteristic assessed via linearity experiment

Precision

Closeness of agreement between a series of measurements from multiple samplings.; Performance characteristic measured by intermediate precision; Performance characteristic to be validated

Linearity

Performance characteristic to be validated

Specificity

Ability to detect intended mechanism of action without interference; Performance characteristic to be validated

Reporting Category

Classification of CMC changes based on risk to product quality; Classification for making changes to approved ECs.

Established Conditions

Legally binding information in a PLCM document

Resin Age

Input parameter evaluated for impact on CQAs

Critical Process Parameter

CPPs that can influence CQAs

Particle Size Distribution

A measurement of the relative proportion of particles in a sample as a function of size.

Technical Details

Substances

6
Active Pharmaceutical Ingredient

examples of such components include but are not limited to the active moiety (API)

Reference standards

impact of changes should be assessed when switching to automated methods

Biotechnological Drug Substances

Scope of manufacturing site transfers in Annex IE

Illustropin

Non-glycosylated recombinant protein used as a biological drug substance example

Host Cell Protein

quantitation of HCP using USP <1132>

Monoclonal Antibody

The antibody portion of an ADC, referred to as mAb

Testing Methods

10
Analytical Procedures

Used to examine samples for physical, chemical or biological changes

Differential scanning calorimetry

spectroscopic or chemical/physical property method

Electrophoretic method

change acceptable where mode of separation remains the same

Mass spectrometry

Used for detection of capsid amino acid modifications.

ELISA

Enzyme-linked immunosorbent assay technique

Reversed-phase chromatography

Example of an analytical procedure physicochemical basis

Analytical characterization methods

Used to demonstrate comparability for site transfers

Stability studies

Initiated on commercial-scale batches at alternate sites

Capillary Electrophoresis

Used in series with mass spectrometry

Near Infrared

NIR probe used for data collection and PAT

Processes

9
Manufacturing Process

Changes to this process may affect the identity and NDI status of an ingredient.; Changes to this process may create an NDI; you should describe the manufacturing process and provide detailed information; includes fermentation as an intrinsic part of identity

Technology transfer

Completed prior to implementation of a new manufacturing site

Process Analytical Technology

system for designing, analyzing, and controlling manufacturing

Powder Blending

Unit operation used as an example for EC identification; Unit operation defined as an Established Condition

Dissolution

Product performance test for an immediate release dosage form

Blending

Combining materials within the same specification to produce a homogeneous intermediate or API

Anion-Exchange Chromatography

one of the two steps focused on in the biological example

Production Culture

unit operation in the manufacturing process

Anion Exchange Chromatography

Unit operation discussed for lifecycle management and established conditions

Clinical Concepts

2
Toxicological data

not warranted as a result of the method change

Clinical data

Presence of clinical data determines whether a full or half application fee is assessed.

Identified Hazards

Hazards

4
Microbial contamination

risk in multidose drug products

Viral adventitious agents

Testing excluded from the simplified analytical change approach

Endotoxin

Output attribute considered an EC in minimal approach

Bioburden

microbiological contamination risk in bulk solution

Standards & References

External Standards

2
Pharmacopoeial monographs

Methods described here are excluded from the structured approach to changes

Pharmacopoeia

recognized standard reference for analytical methods

Specifications

4
Acceptance Criteria

limits for solid state form and particle size; Tightening acceptance criteria; Numerical limits or ranges for tests

System suitability requirements

Criteria for determining if a chromatographic system is functioning properly

Deamidated forms

Acceptance criteria limit of maximum 5.0%

Release specification

May be more stringent than shelf life specification

ICH References (4)

ICH Q12

Technical and Regulatory Considerations for Pharmaceutical Product Lifecycle Management; referenced for established conditions and life cycle management tools; in line with recommendations described in ICH Q12; Guideline for technical and regulatory considerations for pharmaceutical product lifecycle management; Technical and Regulatory Considerations for Pharmaceutical Product Lifecycle Management.

ICH Q5E

Comparability of Biotechnological/Biological Products Subject to Changes in Their Manufacturing Process

ICH Q9

Quality Risk Management recommended for combination products

ICH Q2

discussed in relation to validation and analytical procedure control strategy; Validation of Analytical Procedures guideline used for RTRT validation; Guideline for validation of analytical procedures

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)

Q12 Technical and Regulatory Considerations for Pharmaceutical Product Lifecycle Management Annex | Guideline Explorer | BioRegHub