How to Identify Critical Quality Attributes

and Critical Process Parameters

Jennifer Maguire, Ph.D.
Daniel Peng, Ph.D.
Office of Process and Facility (OPF)
OPQ/CDER/FDA
FDA/PQRI 2nd Conference
North Bethesda, Maryland
October 6, 2015
Opinions expressed in this presentation are those of the speakers and
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do not necessarily reflect the views or policies of the FDA
 Outline
Brief introduction on Quality by Design (QbD)
Example approach to identify critical quality
attributes (CQA)
Example approach to identify critical material
attributes (CMA) and critical process
parameters (CPP)
Illustrative examples
Concluding remarks
2
 What is Quality by Design (QbD)?
 A systematic approach to development that begins with
predefined objectives and emphasizes product and process
understanding and process control, based on sound science and
quality risk management. (ICH Q8 R2)
Systematic Approach
 Define Quality Target Product Profile (QTPP)
Predefined objectives
 Identify Critical Quality Attributes (CQA)
Product and process  Identify critical material attributes (CMA*) and
understanding critical process parameters (CPP)
 Establish the functional relationships that link
CMA/CPP to CQA
 Develop appropriate Control Strategy, including
Process control
justifications
 Science-driven development (scientific literature,
Sound science
prior knowledge, DOEs etc.)
Quality risk management  Risk-based development (ICH Q9)
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* CMA definition will be given later.
What is a Quality Target Product Profile
(QTPP)?
ICH Q8(R2) Definition: A prospective
summary of the quality characteristics of a
drug product that ideally will be achieved to
ensure the desired quality, taking into
account safety and efficacy.

TPP: labeled use, safety

and efficacy

QTPP: quality characteristics

to ensure safety and efficacy as
promised in the label 4
 Guidance for Industry
Q8, Q9, & Q10 Questions and Answers

The Quality Target Product Profile (QTPP)

provides an understanding of what will
ensure the quality, safety, and efficacy of a
specific product for the patient

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 E
X
A
M
P
L
E

Q
T
P
P
QbD for ANDAs: An Example for IR Dosage Forms. April 2012. 6
http://www.fda.gov/downloads/Drugs/DevelopmentApprovalProcess/HowDrugsareDevelopedandApproved/ApprovalApplicat
ions/AbbreviatedNewDrugApplicationANDAGenerics/UCM304305.pdf
 Points to Consider
Guide for ICH Q8/Q9/Q10 Implementation

The Quality Target Product Profile (QTPP)

describes the design criteria for the product,
and should therefore form the basis for
development of the CQAs, CPPs, and
control strategy.

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 Definitions
 Critical Quality Attributes (CQA)
– A physical, chemical, biological, or microbiological
property or characteristic that should be within an
appropriate limit, range, or distribution to ensure
the desired product quality (ICH Q8)
 Critical Process Parameter (CPP)
– A process parameter whose variability has an impact on a CQA and therefore
should be monitored or controlled to ensure the process produces the desired
quality. (ICH Q8)
 Critical Material Attribute (CMA)*
– A physical, chemical, biological or microbiological property or characteristic of
an input material that should be within an appropriate limit, range, or
distribution to ensure the desired quality of output material.

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*CMA is not defined in ICH guidance, but used here for discussion purposes
 Approach to Identify CQAs
1. Consider all DP quality attributes; physical attributes,
identification, assay, content uniformity, dissolution
and drug release, degradation products, residual
solvents, moisture, microbial limits, etc.
2. Identify a CQA based on the severity of harm to a
patient (safety and efficacy) resulting from failure to
meet that quality attribute.
– Identified before taking into account risk control
– Does not change as a result of risk management

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E
X
A
M
P
L
E

Q
T
P
P
10
 Not a CQA

CQA

QbD for ANDAs: An Example for IR Dosage Forms. April 2012. 11

 Definitions
 Critical Quality Attributes (CQA)
– A physical, chemical, biological, or microbiological property or characteristic
that should be within an appropriate limit, range, or distribution to ensure the
desired product quality (ICH Q8)
 Critical Process Parameter (CPP)
– A process parameter whose variability has an impact on a
CQA and therefore should be monitored or controlled to
ensure the process produces the desired quality. (ICH Q8)
 Critical Material Attribute (CMA)*
– A physical, chemical, biological or microbiological property
or characteristic of an input material that should be within
an appropriate limit, range, or distribution to ensure the
desired quality of output material.
*CMA is not defined in ICH guidance, but used here for discussion purposes
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Relationship between CMAs, CPPs and CQAs

CPPs

CMAs Pharmaceutical CQAs

Unit
Input Operation Output
Materials Materials or
Product

CQAs = f (CPP1, CPP2 , CPP3 …CMA1, CMA2, CMA3…)13

Linking Patient - Product - Process
Clinical Outcome
Patient (Safety & Efficacy)

Critical Quality
Product Attributes
(CQA)

Formulation Critical Material Attributes

/Process (CMA)
Critical Process Parameters
(CPP) 14
Example Approach to Identify Material
Attributes and Process Parameters

Useful tools:
Risk assessment, prior knowledge, established science…..

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 Example Approach to Identify Material
Attributes and Process Parameters

Drug Product CQAs: Intermediate CQAs: Process Variables:

Content Uniformity Blend Uniformity 1. Particle size distribution
2. Loading level
3. Number of revolutions

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 Identifying Potentially High Risk MAs or PPs

 Special considerations for unique DS/DP properties

– e.g. RH can be potentially high risk for a hygroscopic formulation

Yu et al, Understanding Pharmaceutical Quality by Design, The AAPS Journal, 2014 , 16(4) 771- 783 17
Example Approach to Determine Criticality
Once potentially high risk variables are identified:
 Identify levels or ranges of these potentially high risk
attributes and/or parameters.
 Design and conduct experiments, using DOE when
appropriate.
 Analyze the experimental data to determine if a
material attribute or process parameter is critical.
– If variability has an impact, then need to monitor and/or control
 Develop a control strategy.

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 Key Points from EMA-FDA QbD Pilot
 Pilot program aimed at a parallel assessment of CMC sections
which are relevant to QbD
 The fact that a risk of failure is mitigated by applying a robust
proactive control strategy should not allow for the
underestimation of assigning criticality.
 Agencies are amenable to the applicant using their own
terminology in the pharmaceutical development section to
communicate development findings
 However, in the 3.2.P.3.3 “Description of the Manufacturing
Process and Process Controls” and 3.2.P.3.4 “Control of
Critical Steps and Intermediates” sections, the description of
all parameters that have an impact on a CQA should be
classified as critical. 19
 Criticality
1. Continuum
2. Focus on the vital few

Increased Control
Increased Risk

3. The control strategy (the

established range) is
important
4. If underlying assumptions
change, then criticality can
change
What's in a name? That which we call a
rose by any other name would smell as
sweet. – William Shakespeare 20
 Schematic Flow Diagram for Identification of
CMAs/CPPs
Can the CQA be No or low potential
impacted by
formulation and
process variables?

Is variable Does studied

Yes shown to be No range capture Yes*
or likely to be intended
practically variability?
significant?

No
Yes

* Changes to the range may impact criticality and need to be re-assessed! 21

Illustrative Examples

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 Example-1
 A fixed-dose combination IR tablet:
– API-1: ~80% of the tablet weight
– API-2: ~1% of the tablet weight
– Diluent (microcrystalline cellulose): ~ 14% of the
tablet weight
– Other excipients: disintegrant, colorant, and
lubricant
– Content Uniformity (CU) of API-2 is a high risk CQA

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 Process Flow Diagram

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 Process Understanding and Control
 Process understanding:
– Ranked all blending steps as medium risk; hence, no
development study was conducted
– Provided testing results of one lab scale batch (4-quart V-
blender, 1.2 kg) and exhibit batch (20 cu. ft. 184 kg)
 Applicant’s control strategy: fix all MAs and PPs for all
blending steps
 Agency’s comment: All MAs and PPs are potentially
critical due to limited characterization of the sources
of variability and inadequate understanding of the
impact of CMAs and CPPs on the drug product CQAs
Knowledge is power ! - Francis Bacon 25
 Example -2
An Extended–Release (ER) Capsule
API: 100 mg
– highly soluble, excellent chemical
stability, no polymorphism
Manufacturing Process:
– Seal-coated sugar sphere core Seal coat

– API coated pellets Sugar

Core
Sphere
API coat

– ER polymer coated pellets ER coat

– Encapsulation and packing

Dissolution is a high risk CQA 26
 ER Polymer Layer Formulation
ER polymer layer:
– Polymer-1 (release controlling, water insoluble)
– Polymer-2 (pore former, water soluble)
– Plasticizer B
– Colorant
Formulation feasibility studies
– Trial with IR pellets + ER pellets (abandoned)
– Effect of Polymer 1 viscosity
– Effect of Polymer 2 type
– Effect of plasticizer type: Plasticizer A vs. B
(hydrophobic vs. hydrophilic)

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 Formulation Optimization
One-factor-at-a-time (OFAT) approach
– Polymer-2 quantity
– Polymer-2 viscosity
– ER layer coating weight gain
Applicant’s conclusion: No impact on
dissolution; hence, these factors are not critical
Agency’s comments: Any interaction? How’s
the range justified? Coating process variability?
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 Further Studies
 ER layer coating weight gain and
Polymer-2 viscosity have strong
interaction.
B: Viscosity

 Both factors are critical!

Disso @ 4h
 Control strategy:
– Using fixed amount of Polymer-
1 and Polymer-2
– Tighten the Polymer-2 viscosity
to the studied ranges instead of A: ER layer coating weight gain
compendial limits
Don’t use insufficiently powered studies to force a favorable conclusion of
non-criticality. The narrow range of ‘non-critical process parameter’ is still
potentially critical. 29
 Example-3
Oral IR tablet: EQ 5mg base
API loading: ~4%
Diluents: microcrystalline cellulose (~60%) and
lactose monohydrate (~30%)
Other excipients: disintegrant and lubricant
Manufacturing Process:
– blending, milling, blend lubrication
– roller compaction and milling, blend lubrication
– compression and aqueous based film coating
Content Uniformity is a high risk CQA 30
Summary of MAs and PPs Evaluated

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Process Development

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 So What is Critical?
The applicant’s conclusion:
– No critical process parameters, intermediates or
process steps have been identified within the
ranges studied during development.
 The Agency did not focus so much on the
terminology, but…
Paid a lot of attention to the studied ranges and
verified if these ranges are captured in the
control strategy, process description, and
master batch record…. 33
 Control Strategy

* Changes to the range may impact criticality and need to be re-assessed! 34

 Example-4
 Oral IR tablet: 2.5 mg and 5 mg
 Drug substance: BCS high solubility, non-hygroscopic, only
one crystalline form known, excellent chemical stability
 API loading: 2.4%
 Diluents: microcrystalline cellulose (~40%) and lactose
monohydrate (~50%)
 Other excipients: disintegrant, wetting agent, and lubricant
 Manufacturing Process:
– blending, screening, lubrication, roller compaction, milling,
blending and lubrication, compression, and film-coating
 Content Uniformity is a high risk CQA
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Process Understanding and Control Strategy
 In-line NIR method to
determine BU and blending
endpoint
 At-line NIR method for tablet
Assay and CU (Large N)
 Other traditional in-process
controls: ribbon density,
ribbon thickness, core tablet
weight & hardness

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 So What is Critical?
 Flexible for input material attributes and process
parameters
 Agency looked carefully at the NIR method,
model development, validation, lifecycle
maintenance plan
 The established NIR method, instrument details,
spectral acquisition and sampling, spectral data
processing, calculation/reporting and the
acceptance criteria are included in P.3.4 “Controls
of Critical Steps and Intermediates”. 37
 Impact on Post-Approval Changes
 Level 1: flexible input material
attributes and process parameters;
real-time automatic controls assure
that CQAs consistently conform to
the established acceptance criteria
 Level 2: flexible material attributes
and process parameters within the
established design space
 Level 3: any significant change in
these MAs and PPs warrants
regulatory oversight
Control Strategy Implementation Options

Yu, et al. Understanding Pharmaceutical Quality by Design, The AAPS Journal, 2014, 16(4): 771-783
38
 Concluding Remarks
 Systematic approach, begin with the end in mind
 Identify CQAs based on patient's needs: safety and
efficacy
 Use science- and risk-based approach to identify
material attributes and/or process parameters that
may impact CQAs
 Prioritize development studies and focus on the vital
few potentially high risk material attributes and
process parameters
 Establish an appropriate control strategy
 Consider discussing lifecycle management plans
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Acknowledgements
 Christine Moore
 Robert Iser
 Rapti Madurawe
 Naiqi Ya
 Ubrani Venkataram

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