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40 Pharmaceutical Technology AUGUST 2017 PharmTech.com Analytics WAVEBREAKMEDIA/SHUTTERSTOCK.COM P ublished in 2004, FDA’s Phar- maceutical cGMPs for the 21st Century, A Risk-Based Approach (1) provided the initial momentum needed to help promote collaborative efforts within the pharmaceutical in- dustry. Designed to modernize phar- maceutical manufacturing and make it more efficient, the guidance highlights the importance of continuous improve- ment to improve efficiency by optimiz- ing processes, reducing variability, and eliminating wasted effort. Reducing variability benefits both patients and manufacturers; there- fore, regulators have voiced strong support for continuous improvement activities. For example, FDA and the International Council for Harmo- nization (ICH) support quality-by- design (QbD)-based product devel- opment. QbD, advanced in ICH Q8 (2), fo- cuses on the use of multivariate anal- ysis in combination with knowledge management tools to understand the impact of critical material attributes and critical process parameters on drug product quality attributes. The heightened product and process un- derstanding that result from using this framework provides a foundation for continuous improvement. Continuous process verification With the implementation of a contin- ued/ongoing process verification pro- gram at Stages 3A and 3B of product development, continual assurance is now available to detect any unplanned departures and allow manufacturers to adjust for them. As outlined in regu- latory guidance on process validation established by regulatory agencies that include FDA (3), the European Medi- cines Agency (EMA), the Pharmaceu- tical Inspection Cooperation Scheme (PIC/S), and the World Health Orga- nization (WHO), process verification identifies any potential risks and initi- ates continuous improvement activities when essential, thus helping prevent likely product failures. Statistical assessment tools However, in order for process verifi- cation to succeed, adequate statistical assessment tools are mandatory. These tools must simultaneously detect unde- sired process variability while guard- ing against overreactions. The pharmaceutical industry uses multiple quality metrics to drive con- tinuous improvement efforts, and FDA is developing guidance (3) to help sim- plify and standardize reporting of metrics. The agency’s draft guidance recognizes the utility of metrics, and recommends that FDA also use them to develop compliance and inspection policies and practices. Regulators at FDA also see these metrics as key to developing practices, such as risk-based inspection schedul- ing, that will help improve the agency’s ability to predict future shortages and to encourage manufacturers to adopt better technologies with low process variability. Senior FDA officials have voiced the agency’s full support and endorsement of continuous improve- ment and innovation in the pharma- ceutical industry. A best estimate of process and method variability identifies the need for continuous improvement, enhances product and process understanding, and allows manufacturers to develop a better control strategy. Sources of vari- A Continuous Improvement Metric for Pharmaceutical Manufacturing Jordan Collins, Naheed Sayeed-Desta, Ajay Pazhayattil, and Chetan Doshi Statistical methods and novel indices can be used to monitor and benchmark variability, and guide continuous improvement programs in late-stage drug development. Jordan Collins is manager of statistical support; Naheed Sayeed-Desta is manager of process validation; Ajay Pazhayattil is associate director of technical operations; and Chetan Doshi is vice-president of product development, all at Apotex, Inc.

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40 Pharmaceutical Technology August 2017 PharmTech .com

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Published in 2004, FDA’s Phar-maceutical cGMPs for the 21st Century, A Risk-Based Approach

(1) provided the initial momentum needed to help promote collaborative efforts within the pharmaceutical in-dustry. Designed to modernize phar-maceutical manufacturing and make it more efficient, the guidance highlights the importance of continuous improve-ment to improve efficiency by optimiz-ing processes, reducing variability, and eliminating wasted effort.

Reducing variability benefits both patients and manufacturers; there-fore, regulators have voiced strong support for continuous improvement activities. For example, FDA and the International Council for Harmo-nization (ICH) support quality-by-design (QbD)-based product devel-opment.

QbD, advanced in ICH Q8 (2), fo-cuses on the use of multivariate anal-ysis in combination with knowledge management tools to understand the impact of critical material attributes and critical process parameters on drug product quality attributes. The heightened product and process un-derstanding that result from using this framework provides a foundation for continuous improvement.

Continuous process verificationWith the implementation of a contin-ued/ongoing process verification pro-gram at Stages 3A and 3B of product development, continual assurance is now available to detect any unplanned departures and allow manufacturers to adjust for them. As outlined in regu-latory guidance on process validation established by regulatory agencies that include FDA (3), the European Medi-cines Agency (EMA), the Pharmaceu-tical Inspection Cooperation Scheme (PIC/S), and the World Health Orga-nization (WHO), process verification identifies any potential risks and initi-ates continuous improvement activities when essential, thus helping prevent likely product failures.

Statistical assessment toolsHowever, in order for process verifi-cation to succeed, adequate statistical assessment tools are mandatory. These tools must simultaneously detect unde-sired process variability while guard-ing against overreactions.

The pharmaceutical industry uses multiple quality metrics to drive con-tinuous improvement efforts, and FDA is developing guidance (3) to help sim-plify and standardize reporting of metrics. The agency’s draft guidance recognizes the utility of metrics, and recommends that FDA also use them to develop compliance and inspection policies and practices.

Regulators at FDA also see these metrics as key to developing practices, such as risk-based inspection schedul-ing, that will help improve the agency’s ability to predict future shortages and to encourage manufacturers to adopt better technologies with low process variability. Senior FDA officials have voiced the agency’s full support and endorsement of continuous improve-ment and innovation in the pharma-ceutical industry.

A best estimate of process and method variability identifies the need for continuous improvement, enhances product and process understanding, and allows manufacturers to develop a better control strategy. Sources of vari-

A Continuous Improvement Metric

for Pharmaceutical ManufacturingJordan Collins, Naheed Sayeed-Desta,

Ajay Pazhayattil, and Chetan Doshi

Statistical methods and novel indices can be used to monitor and benchmark variability, and guide continuous improvement programs in late-stage drug development.

Jordan Collins is manager of statistical support; Naheed Sayeed-Desta is manager of process validation; Ajay Pazhayattil is associate director of technical operations; and Chetan Doshi is vice-president of product development, all at apotex, inc.

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Pharmaceutical Technology August 2017 41

ability can usually be attributed to the “six Ms:” man, machine, material, mea-surement, method, and mother nature. By developing measures of the major sources of variability, a best estimate of the process’ variability (manufacturing method) and analytical (measurement) method variability can be deduced.

The first step in isolating the vari-ability due to the manufacturing pro-cess from the variability due to the analytical method involves defining the response variable, or the critical quality attribute, and the source of data wherein the other sources of vari-ability may be minimized.

The Stage 3A batches, post-Stage 2 pro-cess performance qualification batches, are processed on the same model of qualified equipment (minimizing vari-ability due to machine) by the same pool of trained operators, according to stan-dard operating procedures (reducing any variability that might be created by man).

Raw material used in the process must meet testing specifications and come from a common supplier (to minimize variability due to material), while environmental and facility con-trols and monitoring control the en-vironmental variability (reducing the potential effects of mother nature). By minimizing these four sources of vari-ability, the sources of manufacturing process and analytical method vari-ability can be isolated.

Overall variability can be broken down to its main sources, as shown below [Equation 1].

S2Overall = S2

Process + S2Analytical + S2

Other

[Eq. 1]

Given the controls on other sources of variability found in Stage 3A batches, S2

Other can be assumed to be negligible. Any remaining variability can then be subsumed under the process and ana-lytical sources to yield the partition of interest, namely [Equation 2]:

S2Overall = S2

Process + S2Analytical

[Eq. 2]

Variance component analysisAn estimate of the variability inherent to the process (IPV) and the variability due to the analytical method can then be attained by variance component analysis.

Variance component analysis is a statistical tool that partitions overall variability into individual components. The statistical model underlying this tool is the random-effects analysis of variance (ANOVA) model, which can be written as [Equation 3]:

yij = m + ai + eij where i = 1,…,r and j = 1,…,n

[Eq. 3]

where yij is the jth measurement in

the ith group, m is the overall mean (an unknown constant), a

i is the effect at-

tributable to the ith batch, and eij is the

residual error. It should be noted that, in this

model, as opposed to a fixed-effects ANOVA model, a

i is considered to

be a random variable, where random conditions include different chemists, equipment, batches, and numbers of days (4). The random variables a

i and

eij are assumed to be independent, with

mean zero and variance σ2a and σ2

e, re-spectively (5–7).

IPV measures batch-to-batch variabilityInherent process variability (IPV) is a measure of batch-to-batch variability, while analytical (method) variability is a measure of the variability of material within the same batch (8). As such, es-timates of σ2

a measure inherent process variability, while σ2

e measures analyti-cal method variability.

Other measures of interest can be obtained from the above model. For instance, the ratio of these two variance components σ2

a σ2eθ = , provides a stan-

dardized measure of the variance of the population group means, while the in-tra-class correlation σ2

a σ2eσ2 +a θ θ+1ρa = =

is a measure of the proportion of the total variance due to the process.

Estimates for these values can be ob-tained from the ANOVA data provided in Table I as follows [Equation 4]:

σ2 = MSEe

ρa =

σ2 =a

〈〈

MSA-MSEn

MSA-MSEnMSE

MSA-MSEMSA+(n-1)MSE

θ =

[Eq. 4]

Other estimators are available, in particular for unbalanced data where a different number of measurements are taken per batch. The restricted maxi-mum likelihood (REML) estimator is a viable alternative available in most statistical software packages.

Table I: The random-effects analysis of variance (ANOVA) table.

Source of variation Degrees of freedom Sum of squares Mean square Expected mean square

between groups (Process)

r-1 SSA = n∑ri=1(yi.– y..)

2 MSA = SSA(k-1) nσ2

a σ2 e+

within groups (analytical)

r(n-1) SSE = ∑ri=1∑

nj=1(yij– yi.)

2 MSE = SSEk(n-1) σ2

e

total rn -1 SST = ∑ri=1∑

nj=1(yij– y..)

2

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42 Pharmaceutical Technology August 2017 PharmTech .com

This model can be fit to situations in which the batch effect is considered random, and each batch has n samples. For example, 20 batches might be con-sidered to be a random sample from a larger pool of batches for a specific product. For each of these 20 batches, a random sample of 10 samples would be taken to measure finished product dosage uniformity.

The variability in the mean finished product dosage uniformity between the batches, σ2

a

, would yield an esti-mate of the inherent process variability, while ρa

would provide an estimate of the proportion of variability due to the process. Confidence intervals can be constructed for these estimates and are available in common statistical software packages.

Focusing on process improvementThe estimated IPV, as well as the ratio of total variance due to the process, can be used during Stage 3 batch monitoring to focus efforts on process improvement. As more in-formation is gathered for a product, a rise in the IPV itself, or a rise in the proportion of total variance due to the process ( ρa

) could indicate the need to investigate possible process improvements.

On the other hand, a decrease in IPV or the decline in ρa

would indi-cate that the process is improving. In order to obtain a picture of how well the process is performing overall for a specific product, a comparison with other products employing the same process can be made by generating a benchmark.

The novel PaCS index (named for the first letters in the authors’ last names: Pazhayattil, Collin, and Sayyed-Desta) provides an indication of a current product’s process perfor-mance in comparison to other similar products. To derive the PaCS index, a representative set of other products generated with the same process would be chosen.

For each of these chosen products, the IPV would then be calculated as above. The PaCS index could then be

calculated using the following equa-tion [Equation 5]:

PaCS = IPVP/ IPV

B

[Eq. 5]

where IPVB is the benchmark in-

herent process variability and IPVp

is the inherent process variability for the product under consideration. IPV

B is the median process variabil-

ity of the selected products with pro-cesses similar to the current product. Lower value preferredA PaCS index greater than 1 indicates the process variability is high, while a PaCS less than 1 indicates that pro-cess variability is low compared to the benchmark. Therefore, a PaCS value that is less than 1 is preferred.

Because the distribution of the PaCS index is not analytically deriv-able, confidence intervals can be esti-mated using Monte Carlo simulation. The PaCS index together with IPV values and the other derived statis-tics provide a platform upon which further decision making can take place. For instance, high PaCS values would indicate that the process for a specific product is not performing as expected.

Estimation of inherent process vari-ability (IPVP) allows for determining a PaCS index for the product, and helps in understanding the contribution to variability that comes from the manu-facturing process and the analytical method used. In addition, PaCS is a metric developed in relation to the manufacturing process at a particular production site.

Decision making toolThe index can be effectively used to determine continuous improvement projects at the site or for site transfer initiatives. PaCS provided with a tan-gible quantitative robustness figure for various supply chain decision making. The index can be a component of pe-riodic process performance review by senior management as recommended by ICH Q10 (9).

In addition, APV and the PaCS Index may be used to decide such things as who should be primarily responsible for a specific continuous improvement project (i.e., whether process, analytical, or a combination). This is often a point of contention.

It could also be used to determine which site has the best PaCS index with respect to a product. This factor will be considered when deciding for or against site product volume increases.

In summary, the PaCS can provide valuable insight to decision makers, and help to drive continuous quality improvement programs in biopharma-ceutical and pharmaceutical develop-ment as well as manufacturing.

References 1. FDA Final Report, Pharmaceutical

cGMP’s for the 21st Century- A risk based approach, fda.gov, Sept. 2004, www.fda.gov/Drugs/DevelopmentApprovalPro-cess/Manufacturing/

2. ICH Q8 (R2), Pharmaceutical Develop-ment, (ICH, August 2009), ich.org, www.ich.org/fileadmin/Public_Web_Site/ICH_Products/GuidelinesQuality/

3. FDA, Draft Guidance, Submission of Quality Metrics Guidance, (FDA, No-vember 2016), fda.gov, www.fda.gov/downloads/Drugs/GuidanceCompli-ance RegulatoryInformation/Guid-ances/UCM455957.pdf

4. K. Barnett K et al., “Analytical Tar-get Profile: Structure and Application Throughout the Analytical Lifecycle,” USP Stimuli to the Revision Process (42) 2016, pp. 1-15.

5. R.K. Burdick, and F.A. Graybill, Confi-dence Intervals for Variance Components (Marcel Dekker, New York, 2006).

6. S.R. Searle et al., Variance Components (John Wiley, New York, 2006).

7. H. Sahai, H. and M. Ojeda, Analy-sis of Variance for Random Models. (Birkhäuser, Boston, 2006).

8. B. Nunnally, “Variance Component Analysis to Determine Sources of Varia-tion for Vaccine Drug Product Assays,” Journal of Validation Technology, Sum-mer 2009; pp. 78-88, available online at www.ivtnetwork.com/sites/default/files/ProductAssays_01.pdf.

9. ICH, Q10 Harmonized Tripartite Guide-line, Pharmaceutical Quality Systems, (ICH, June 2008), ich.org, www.ich.org/fileadmin/Public_Web_Site/ICH_Prod-ucts/Guidelines/Quality/Q10/Step4/Q10_Guideline.pdf PT

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