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Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are not specified in the license be handled and what will be the agency involvement? Are there additional considerations beyond criticality of a given attribute that factor into the control strategy development? Are Expanded Change Protocols (eCP) and EU Post Approval Change Management Protocols (PAMP) the same? If not, what are the key differences?

Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Page 1: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

Workshop Session 3 Questions

1

•How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are not specified in the license be handled and what will be the agency involvement?•Are there additional considerations beyond criticality of a given attribute that factor into the control strategy development?•Are Expanded Change Protocols (eCP) and EU Post Approval Change Management Protocols (PAMP) the same? If not, what are the key differences?

Page 2: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Antibody Process Platform

Antibody Process Platform

Critical Quality Attributes

Key PerformanceIndicators

Illustrate Relationship of Process to Product

Critical Material Inputs

Critical Process

Parameters

Key Process Parameters

Target Product Profile

Target Product Profile

Control of Critical Inputs and Process Parameters

Design Space

Ensure Control ofCritical Outputs

Vaccine

Slide from Lynne Krummen (Genentech)

Page 3: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Example: Vaccine Protein Fragmentation

Fragment 1

Fragment 3

Fragment 2

Intact Protein(Immunogenic)

ImmunogenicNon-immunogenic

Non-immunogenic

Page 4: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Is Fragmentation a CQA?

Impact: 8 (medium)Literature identifies potential impact of fragments (decreased immunogenicity)

Green: low impactYellow: medium impact

Category

Risk Assessment

Impact on Efficacy Impact on Safety

Immunogenicity Toxicity

Literature or similar products

Available literature on potential impact

Info on potential impact based on similar products

Laboratory experienceTest fragments and fragment enriched samples

to assess impact  

Non-clinical experience Assess impact in animal models

Clinical experienceEfficacy and safety results from clinical study 8 4

Page 5: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Process Capability

Immunogenicity operating space

Both processes result in a product with a highly consistent fragmentation profile

Fragm

ent 1

Fragm

ent 3

Fragment 2

Page 6: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Control Strategy

Fragmentation

Impacted by

Production scale up X 

Manufacturing site

Cell Line XRaw materials  Production bioreactor X Harvest  Cation exchange chromatography XAnion exchange chromatography X Nanofiltration  Low pH inactivation X Hydroxyapatite chromatography  Formulation  

Criticality of attributes

Controls

Raw material control  Process clearance capability  Critical operational parameters X Procedural controls  Process validation  In-process control X Lot release testing X Stability testing X Characterization testing X

Page 7: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Risk Analysis (Likelihood)

Manufacturing process consistently produces material that is well within the range of the prior product knowledge

Vaccine processes result in products with different proportions of the same fragments having similar safety and efficacy

In this case, fragments have low impact if they are controlled within a range

Therefore, the likelihood of adverse effect occurrence due to variation in fragmentation proportions is very low

Page 8: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Overall Process Risk Minimized

Ris

k in

dex

Raw

mat

eria

ls

Pro

duct

ion

Bio

reac

tor

Har

vest

Cat

ion

Exc

hang

e

Ani

on E

xcha

nge

Nan

ofilt

ratio

n

Low

pH

Inac

tivat

ion

Hyd

roxy

apat

ite

For

mul

atio

n

Raw

Mat

eria

l Con

trol

Pro

cess

Cap

abili

ty

Ope

ratio

nal P

aram

eter

s

Pro

cedu

ral C

ontr

ols

In-P

roce

ss C

ontr

ols

Lot R

elea

se T

estin

g

Sta

bilit

y T

estin

g

Cha

ract

eriz

atio

n T

estin

g

0

0.5

1

1.5

2

2.5

3Aggregate

Fragment

Deamidation

HCP

Insulin

Glycosylation

DNA

#REF!

Page 9: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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July 2010

Where Innovation Operates

ManagementConsultants

Quality by Design

VACCINE-BASED CASE STUDY

Sam VenugopalPrincipal

T +1 650.864.3522F +1 650.967.6367M+1 408.396.9649

[email protected]

444 Castro StreetSuite 400Mountain View, CA 94041U.S.A.

www.prtm.com

John BerridgePharmaceutical Ccnsultant

T + 011447971324939

[email protected]

Bracklyn, St. Clare RoadWalmerDeal CT14 7QB

Page 10: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Questions for discussion

What challenges would there be to justifying the described immunogenicity design space?

What studies would be needed for a therapeutic protein to justify an immunogenicity “design space”, where immunogenicity is undesirable?

Page 11: Workshop Session 3 Questions 1 How would a control strategy look different in a traditional submission vs a QbD submission? How would parameters that are

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Questions for discussion

QbD has several elements that can be applied across multiple product types and associated systems. What are the essential components of QbD that can be applied most generally?

What elements of QbD appear to be the most difficult/costly/time consuming?

How are companies making decisions over how much, if at all, QbD will be applied to a particular product, especially considering early phase, late phase and licensed products?

Global acceptance of QbD by regulators is one barrier to the implementation of QbD on a holistic basis. How are companies managing with global filings? What other concerns do companies have in implementing QbD?

Apart from process and product, on what other applications can QbD have an impact?