J Pharm Innov (2008) 3:95104

DOI 10.1007/s12247-008-9035-1

PRODUCT QUALITY LIFECYCLE IMPLEMENTATION (PQLI) INNOVATIONS

PQLI Control Strategy Model and Concepts

Bruce Davis & Line Lundsberg & Graham Cook

Published online: 17 May 2008

# International Society for Pharmaceutical Engineering 2008

Abstract This paper describes an approach and technical

process for developing and implementing a Control Strategy,
which is a planned set of controls, derived from current
product and process understanding that assures process
performance and product quality. Development of a Control
Strategy requires a structured process, involving a multidisciplinary team of experts, linking pharmaceutical development to the manufacturing process, and engineering controls
of process equipment. The PQLI Control Strategy Team has
proposed a Control Strategy Model that facilitates understanding and that may be used a cross-functional communication tool. This paper concentrates on the techniques and
principles involved in developing the early Control Strategy
rather than the operational implementation of the strategy.
Keywords PQLI . Design space . Criticality .
Control strategy . Critical quality attribute .
Tom Garcia - Pfizer, Stephen Tyler - Abbott, Eric Ahuja - Merck,
Metter Bryder - Lundbeck, Michael Hahn - Lundbeck, Ray Bolton AstraZeneca, Gordon Muirhead - GSK, Sue Busse - Lilly, Hedinn
Valthorsson - Novartis
B. Davis
AstraZeneca,
Alderly House, Macclesfield,
Cheshire SK10 4TF, UK
e-mail: [email protected]
L. Lundsberg
NNE Pharmaplan,
29 Pine Walk,
Cobham KT11 2HJ, UK
e-mail: [email protected]
G. Cook (*)
Wyeth Pharmaceuticals,
New Lane,
Havant PO9 2NG, UK
e-mail: [email protected]

Critical process parameter . Knowledge space . PAT .

Pharmaceutical target product profile . Product and process
knowledge . Quality by design . Quality risk management .
API . Drug substance . Drug product

Introduction
The Product Quality Lifecycle Implementation (PQLI)
initiative [7] was launched by ISPE to help industry
identify global solutions to the challenges in implementing
ICH Q8, Q9 and Q10 guidance [3, 5, 6], and to provide the
technical framework for the implementation of key elements of Quality by Design (QbD) [1, 2, 8, 9, 11, 14, 15].
QbD is a systematic approach to product and process
design and development. One of the key elements is design
and implementation of a Control Strategy.
Control Strategy is defined in the ICH Q10 (Step 2) [6]
document as:
A planned set of controls, derived from current product
and process understanding that assures process performance and product quality. The controls can include
parameters and attributes related to drug substance and
drug product materials and components, facility and
equipment operating conditions, in-process controls,
finished product specifications, and the associated
methods and frequency of monitoring and control.
This Control Strategy for a particular product should be
established within the framework of the overall Pharmaceutical Quality System (PQS). The Control Strategy is a
comprehensive plan for ensuring that the final product meets
critical requirements, and therefore the needs of the patient.
Elements of a Control Strategy can include (but are not
limited to) the following:

96

&

&
&
&
&

&

J Pharm Innov (2008) 3:95104

Control of input material attributes (e.g., drug substance, excipients, primary packaging materials) based
on an understanding of their impact on process-ability
or product quality
Product specifications
Procedural controls
Facility controls, such as utilities, environmental systems and operating conditions
Controls for unit operations that have an impact on
downstream processing or end-product quality (e.g. the
impact of drying on degradation, particle size distribution of the granulate on dissolution)
A monitoring program (e.g., full product testing at regular
intervals) for verifying multivariate prediction models

The Control Strategy should establish the necessary

controls - based on patient requirements - to be applied
throughout the whole product lifecycle from product and
process design through to final product, including API and
Drug Product manufacture, packaging and distribution.
This paper describes an approach and technical process
for developing and implementing a Control Strategy.
This paper concentrates on developing the early Control
Strategy and the principles behind this. Full details of what
is required at every stage of the lifecycle have not been
included, but could be developed from these principles.
This should be regarded as work in progress and
comment and input from industry, regulators, and suppliers
is welcomed.

Minimal and Enhanced Approaches

As in ICH Q8(R) (Step 2) [4], a distinction may be drawn
between a minimal and an enhanced control strategy
approach.
In a Minimal Control Strategy, drug product quality is
controlled primarily by intermediate and end product testing.
With an Enhanced Control Strategy drug product quality
ensured by risk-based control strategy for well understood
product and process, and quality controls are shifted
upstream, with the possibility of real-time release or
reduced end-product testing. A Design Space is established,
and the Control Strategy will ensure that the product is
manufactured within the Design Space.
Other aspects may include:
&
&
&

Product specifications are part of the overall quality

control strategy, and based on desired product performance with relevant supportive data
Appropriate feed forward and feedback controls to
provide a more reproducible product
Process operations tracked and trended to support
continual improvement efforts

Whether a minimal or enhanced approach is applied, the

Control Strategy must be made operational, for example, by
incorporating certain elements in the batch record and
enabling execution of the Control Strategy to be linked to
the decision to release the product. This paper does not
cover these operational aspects.

Developing the Control Strategy

Development of a Control Strategy requires a structured
process, involving a multi-disciplinary team of experts,
linking pharmaceutical development to the manufacturing
process, and engineering controls of process equipment.
The PQLI Control Strategy Team has proposed a Control
Strategy Model that facilitates understanding and that may
be used a cross-functional communication tool. This is
described in detail later in this paper.
Personnel at all levels should be able to understand the
way control strategy links from CQAs to operational
aspects to ensure, for example that:
&

&
&

Chemists understand in-process controls are established

to keep the process inside the design space and seek
opportunities for simplification of controls, as knowledge is gained.
Engineers know how equipment operating conditions
impact product quality.
Quality Assurance professionals know where the highest risks are in the process.

Although the primary driver for development of a

control strategy will be assurance of product safety, efficacy
and quality, the Control Strategy may also ensure the
meeting of other business objectives such as operator health
and safety, protection of the environment, manufacturability, supply related issues, efficiency, and profitability.
Development of a Control Strategy for a product will
therefore be a structured and iterative activity involving a
multi-disciplinary team of experts. This team may include
representatives from formulation development, drug substance development, process development, analytical development, QC, QA, Regulatory Affairs, manufacturing,
engineering, and specialists in Process Analytical Technology (PAT) and chemo-metrics.
Existing risk assessment tools such as HACCP
(Hazard Analysis and Critical Control Points), Worst
Outcomes Analysis FMECA (Failure Mode Effects and
Criticality Analysis) [10] can provide a framework for
Quality Risk Management.
A Control Strategy and a product release strategy are not
the same, but demonstration of adherence to the Control
Strategy would support the product or batch release
strategy.

J Pharm Innov (2008) 3:95104

Control of Input Material Attributes

Variability in the manufacturing processes may be caused
by variability in the drug substance and raw materials and
their attributes, when linked to a CQA.
The impact of not only chemical but also physical
material attributes and their variability need to be understood. For example, for an oral solid dosage product,
impact of factors such as participle size distribution, particle
shape distribution, density, surface area, surface energy,
flow, cohesiveness, friction, elastic modulus, amorphous
content, compactibility, hygroscopicity, solubility, and static
charge should be assessed.
A linkage between the product CQAs and the input
material attributes should enable identification and understanding of the most critical material attributes and their
impact on the product CQAs.
Controlling the variability of input materials can be
managed in different ways, e.g. by functional specifications
(not necessary in concurrence with compendia specifications) or by managing the variability directly in the process
using closed loop controls.
One example is raw materials affected by seasonal variations
in the moisture level and used in a moisture critical blend. By
applying PAT tools such as NIR (Near Infrared) spectroscopy,
drying can be monitored on-line and the drying process
controlled to the end-point with a closed feed-backward control
loop in place (see [12, 13]). In many cases the variability in a
material input can be managed by operating the process
conditions differently within the Design Space.
Other input materials such as packaging material should
be studied during development to identify and understand
which material attributes impact the manufacturing process
and final product CQAs.
In-Process Controls
In-process controls include all controls that need to be
performed during processing, including control of Critical
Process Parameters, in-process material attributes and components, as well as equipment and facility parameters that
must be monitored or controlled to achieve the product CQAs.
Controlling the Critical Process Parameters during
processing is important as they have a direct impact on
the CQAs, but other parameters (that may be part of a unit
operation), that have an impact on downstream processing
or other end-product quality attributes not already covered
by a CQA, should be monitored or controlled as well.
Which parameters to monitor or control is the outcome of
Quality Risk Management (QRM) activities aimed at
mitigating the risks arising during manufacturing.
In-process controls could include conventional sampling
and at-line analysis or on-line or in-line univariate sensors

97

or multivariate probes (typical spectroscopy). They may be

manual or automated, depending on the nature of the
process itself, what needs to be measured and controlled,
how often, scale, process time, and the nature of the
manufacturing equipment.
Verifying Multivariate Prediction Models
Implementing PAT for in-process and or release controls relies
heavily on the application of multivariate prediction models,
also known as process models. These models can either
predict CQAs or CPPs or a combination of both. The nature of
these models requires frequent updates. How frequently
depends on the maturity of the model (e.g. the amount of
data and their variability within the model), as well as the kind
of data that has been included to reflect variability in scale,
equipment, analytical set-up, sampling, or site.
A monitoring program for verifying the models should
be established and be based on a risk assessment of the
model itself and include possible ways to verify the model
by other means e.g. by comparing the predicted CQA value
to a conventional analytical method. Verifying predicted
CPPs can sometimes be difficult because, for example,
sampling is not possible or there are no conventional
laboratory methods. In these cases other ways of verification should be proposed. The monitoring program should
include requirements for when a model has to be updated
(e.g. latest batch information, change of raw material
supplier, increased knowledge and experience over time).

Control Strategy Model

The ISPE PQLI Control Strategy Team has proposed a Control
Strategy Model that facilitates understanding and that may be
used a cross-functional communication tool (see Fig. 1).
The model seeks to link the attributes of the product that
are important to the patient, to the controls in the manufacturing process that are needed to deliver those attributes, and
also to show in parallel the business requirements.
The starting point is normally the Critical Quality
Attributes (i.e evolved from the desired Pharmaceutical Target
Product Profile) and the end point is the distribution of
manufactured product itself. The Control Strategy should
link from pharmaceutical drug development through manufacturing including process engineering equipment control.
This model shows:
&
&

Three levels showing links from the finished product

CQAs and other objectives through the manufacturing
operations to the controls by which these are achieved.
Two columns distinguishing between patient and business requirements.

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J Pharm Innov (2008) 3:95104

Fig. 1 The PQLI control strategy

model

PQLI Control Strategy Model

Control
Strategy
Level 1

Control
Strategy
Level 2

Control
Strategy
Level 3

PATIENT

BUSINESS

Product:
Product:CQAs
CQAs
For
Forpatient
patientsafety,
safety,
efficacy
efficacyand
andquality
quality
(as
(asICH
ICHQ8/Q6a)
Q8/Q6a)

Other
OtherProduct
ProductAttributes
Attributes&&
Business
BusinessRequirements
Requirements
e.g.
e.g.cost,
cost,safety,
safety,
environmental,
environmental,
manufacturability
manufacturability

Controls
Controlsto
toEnable
Enable
Product
ProductCQAs
CQAsto
tobe
bemet
met
e.g.
e.g.CPPs,
CPPs,material
material
attributes
attributes&&components,
components,
equipment
equipmentand
andfacility
facility
operations
operationsthat
thatmust
mustbe
be
monitored
monitoredor
orcontrolled
controlledto
to
achieve
achieveproduct
productCQAs
CQAs

Other
OtherControls
Controls
Other
Otherparameters
parametersand
and
material
materialattributes
attributes&&
components,
components,equipment
equipment&&
facility
facilityoperations
operationsthat
that
must
mustbe
bemonitored
monitoredor
or
controlled
controlledto
toachieve
achieve
other
otherproduct
productattributes
attributes&&
business
businessrequirements
requirements

Analytical,
Analytical,Engineering
Engineering&&Other
OtherControl
ControlMethods
Methods
Analytical
Analyticalmethods
methods(off
(offline,
line,at-line,
at-line,in-line,
in-line,or
oron-line)
on-line)
Equipment
Equipmentand
andfacility
facilityengineering
engineeringcontrols
controls
PAT
PAT(including
(includingprocess
processmodels
modelsand
andcontrol
controlmodels)
models)
Automation
Automationand
andmanual
manualcontrols
controls
Procedures
Procedures

At Level 1 the Critical Quality Attributes (CQAs) and

other requirements are identified.
Level 2 considers the critical process parameters,
material attributes and components involved in meeting
the CQA requirements.
Level 3 covers the actual analytical, automation, and other
controls of the Level 2 identified parameters and attributes.
Note that product specific patient-related Quality Attributes need to work within a Pharmaceutical Quality System
(PQS), as per ICH Q10 (shown by the dark blue
background to the Patient side) whereas business-related
product aspects may be governed by other requirements,
(shown by the light blue background to the Business side).
The exact boundary between the PQS and the systems to
facilitate other business controls (dark and light blue boundary)
is linked to the overall design of a companys work processes.
The term Control Strategy can mean different things to
different functions. Engineers often use the term Control
Strategy to mean how plant and equipment is controlled to
enable manufacture, and although this may be true at plant
level, it is important that the plant level requirements have a
logical link back to both patient and business product
requirements, and support the Pharmaceutical Quality
System and business systems.
The model highlights areas of importance, i.e. related to
patient safety, efficacy and quality and serves as a
framework for understanding the future controls that need
to be established and how they will impact the batch release
strategy. The Model logic may facilitate regulatory
discussion.

PQS (ICH
Q10) incl
GMPs

Systems
to
facilitate
other
business
controls

Application of the Model

At Control Strategy Level 1 the Critical Quality Attributes
(CQAs) of the product are identified. Those product Quality
Attributes that directly relate to patient safety, efficacy and
quality are derived from the Pharmaceutical Target Product
Profile using prior knowledge, clinical experience and
product and process understanding.
Business requirements that are not directly related to
patient safety, efficacy and quality but are important to the
business are also identified. These may include cost,
efficiency, operator safety, environmental protection, manufacturability, other customer needs, and supply related
objectives. This concept of manufacturability relates to
the attributes of a product that are not directly related to
patient safety, efficacy or quality (included in a specification approved as part of a regulatory submission), but
which may be important for customer satisfaction, such as
minimizing cosmetic defects.
For an oral solid product, Drug Substance attributes
considered may include appearance, identity, polymorphism, crystal habit, assay, surface energy, impurities,
solvents, water content, particle size, sulphonated ash, and
metals. For Drug Product, attributes such as friability,
identification, appearance, dissolution, assay, content uniformity, degradation, purity, microbiology, and packaging
are normally considered.
Decisions on what is critical or non-critical are taken,
and may be based on criteria and concepts discussed in the
related paper PQLI Criticality [16] in this Volume of the

J Pharm Innov (2008) 3:95104

Journal of Pharmaceutical Innovation. As process understanding and product and process experience grow, this
knowledge can be applied to continuously improve the
process (ICH Q10). An attribute that was thought to be
non-critical may turn out later to be critical, or vice versa.
Companies will typically determine what is critical or
otherwise based on a risk assessment and then develop a
Control Strategy from this basis to ensure the product
remains within the Design Space. Note that a Control
Strategy or test does not make a CQA or CPP non-critical;
but rather makes it controlled.
Some companies may choose several levels of criticality
to describe multiple levels of risk, e.g. the use of the terms
key or important as well as critical and noncritical. For example, as process parameter boundaries
approach edges of the proven acceptable range (PAR) or
failure point, if known, the level of criticality normally
increases with the level of risk. Companies may decide to
define an additional category to address those parameters
that are lower risk than for critical process parameters e.g.,
a product parameter is well controlled in relation to the
required boundaries and is of lower risk, and therefore
would only be described in the Pharmaceutical Quality
System.
Control Strategy Level 2 considers the means by which
the CQAs and other business requirements determined at
Control Strategy Level 1, will be assured e.g. what
attributes of the starting materials, reagents, solvents,
process aids etc. must be monitored or controlled, and
what parameters and operating conditions of the process
equipment and manufacturing facility need to be monitored
or controlled to ensure the objectives defined at Control
Strategy Level 1 are achieved.
CQAs can be measured and evaluated directly or,
alternatively, indirectly for raw material or other material
attributes identified to impact the CQAs. The control of all
CPPs and those process parameters contained in the
intermediate category (if applicable), should ensure the
CQAS are being delivered and hence the process is
maintained within the Design Space
At Control Strategy Level 3 the analytical and other
controls methods are described. The information will
include the measurement technologies for the material
attributes or equipment parameters (off-line, at-line, in-line
or on-line), univariate or multivariate process models and
control models, as well as procedural and engineering
controls of the plant including automation systems, closed
control loops, normal operating ranges, and alarms.
Note that controlling plant and equipment covers both
sides of the model and, practically, cannot be separated (e.g.
a PLC, a plant controller or a data capture system will be
set up to control all parameters). There will not be two
separate engineering control systems, such as one for

99

patient-related product requirements and one for businessrelated requirements.

Level 3 should also provide information about the
intended multivariate process models to be used, including
what these process models will do, and how they will be
operated and maintained. The process model should be
maintained within the companys own Pharmaceutical
Quality System.
The Control Strategy is implemented within a framework comprising the Pharmaceutical Quality System and
Good Manufacturing Practices for the patient-related
product attributes, and other aspects such as Environmental,
Health and Safety systems, and financial systems for the
business-related requirements. Certain aspects of the business-related requirements and controls may need to be
described in the Control Strategy for the patient-related
aspects to facilitate an understanding of the logic and
rationale for the Control Strategy as a whole.

Developing and Implementing a Control Strategy

Once the product CQAs have been identified at Control
Strategy Level 1, the Control Strategy Level 2 can be
developed, by addressing questions such as:
&
&
&

What needs to be controlled?

Where in the process does control need to be implemented?
Which quality attributes of the starting materials,
intermediate materials, reagents, components, and process parameters and operating conditions of the process
equipment and facility systems must be controlled to
assure a final product CQA?

For each finished product CQA the factors to be

considered include:
&

&
&
&
&
&

Physical, chemical and biological attributes of the

starting materials, reagents, components and in-process
material used to manufacture the drug substance and
drug product
Equipment operation and design, parameters and operating conditions in the manufacturing process for the
drug substance and drug product
Facility utilities, environmental systems and operating
conditions
Specifications or acceptance criteria for the attributes
and parameters considered above
Facility and process standard operating procedures
Risks associated with failure of an element of the
control system

At Control Strategy Level 2 a number of different

approaches may be adopted to control a CQA - hence

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J Pharm Innov (2008) 3:95104

leading to the selection of one particular Control Strategy

over another.
Control Strategy Level 3 addresses questions such as:
&
&
&
&
&
&

How are these critical process parameters and material

attributes controlled so that product quality is assured?
What happens if a control fails?
Can failure be detected?
How can the risk to product quality be mitigated?
Can a back-up or secondary control be used?
How is the control implemented?
Typical controls include:

&
&
&
&
&
&
&

Off-line testing of an attribute of a starting material,

component or in-process material
Monitoring and feedback control of a material attribute
during processing (manual or automated)
Monitoring and feedback control of an equipment
parameter during processing (manual or automated)
Monitoring and feed-forward control of a material
attribute or process parameter (manual or automated)
Procedural control of an operation
Equipment and facility design
Process design, for example the addition of specific
operations during drug substance manufacture to reduce
the level of impurities

Details to consider when implementing a control

include:
&
&
&
&

Methods and frequency of monitoring and control

Sampling, including sample size and sampling methodology
Calibration of analysers and sensors
Procedures to be followed in the event of a malfunction

Risk Assessment during the Development of a Control

Strategy
A risk assessment of the manufacturing process may need
to consider a number of factors, including reliability of the
control system and malfunction procedures, or the need for
redundancy, such as replication of sensors and other
elements of the system to ensure control in the event of a
failure.
Risk mitigation for a critical measurement may include
an additional sensor or an alternate means of confirming
conformance to the acceptance criteria e.g. through use of
first principles or off-line testing to demonstrate a state of
control. If a process model is critical to assuring the
operation remains within the Design Space then the failure
of an analyser or sensor (e.g. sending incorrect data to the
model), the control (e.g. responding incorrectly to an output

from the model) or the model itself to work as intended

should be considered.
An example of how the proposed model can be used
with the Hazard Analysis and Critical Control Points
(HACCP) seven step process is given below.
&
&
&

Step 1 in the HACCP process defines Control Strategy

Level 1 (definition of the CQAs of the finished product)
Steps 2 4 define Control Strategy Level 2 (the what
and where)
Steps 5 6 define Control Strategy Level 3 (the how):
1. Define the product and process

Understand the product (dosage form, pack,

storage, therapeutic use, patient population etc.)
Define Finished Product CQAs
Prepare a process flow map

2. Identify the potential hazards and potential control

measures
What factors affect the finished product CQAs?
(starting materials, equipment, personnel, environment etc.)
What are the Critical Process Parameters?
What are the starting material and in process
material CQAs?
3. Determine the Critical Control Points
Where must control be implemented?
4. Establish the Critical limits for each Critical
Control Point
May be derived from Design Space
May determine the nature of technology used
for monitoring and control
5. Establish a monitoring system for each Critical
Control Point
e.g. timely data for feedback control of process
6. Establish Corrective Action plans to re-establish
control when necessary
Use of secondary controls
7. Establish Verification procedures to demonstrate
compliance
Qualification of controls
Trending of data
Periodic quality review

Control Strategy Verification

Once a Control Strategy has been developed it should be
implemented and verified under the companys Quality
Management System. A robust change control system

J Pharm Innov (2008) 3:95104

should be in place to document changes, assess the impact

and ensure that changes do not adversely affect the Control
Strategy and thereby the intermediate or final product
quality.
Verification of the Control Strategy will involve an
assessment that the controls will ensure the product CQAs.
This may include verification of the individual controls and
continuous quality verification of the manufacturing
process.
When implementing PAT, verifying predicted CPPs can
be difficult, because sampling is not possible, for example,
because there are no conventional laboratory methods. In
these cases alternate approaches to verification should be
proposed.

Control Strategy and the Product Lifecycle

The Control Strategy is related to the level of process
understanding at a given time, and evolves as manufacturing experience increases. The originally specified measures,
controls or models may be modified or even removed, or
the need for additional controls may be identified. Other
revisions to the Control Strategy may relate to continual
improvement, for example the introduction of improved
analyser or control technology.
Periodic reviews of risk assessments and mitigation
should be conducted to determine the appropriateness of
the Control Strategy based on product manufacturing
history. Failure or deviations should be investigated and
the effectiveness of the control system considered in
relation to the identified root cause. Corrective and
preventive actions should be applied and the Control
Strategy updated as necessary (including any regulatory
actions required) in the light of new product and process
knowledge.
Implementing PAT in the Control Strategy will require
the application of process models (multivariate prediction
models) that either predicts CQAs or CPPs or a combination of both. These models may require frequent updates,
depending on the maturity of the model (e.g., the amount of
data and their variability within the model), as well as the
kind of data that has been included to reflect variability in
scale, equipment, analytical set-up, sampling, and site. A
monitoring program for verifying the validity of process
models should be established and be based on a risk
analysis of the model itself and include possible ways to
verify the model by other means. One example would be to
compare the predicted CQA value to a conventional
analytical method. The monitoring program should include
requirements for when a model has to be updated (e.g.
change of raw material supplier or deviations resulting in
increased knowledge).

101

Case Study Example 1

The following is an example from manufacturing a drug
substance. In this case, impurity A has been identified as
critical, whereas impurity B has no impact on patient safety
and efficacy.
Control Strategy Level 1
Impurity A is identified as a CQA. There is a business
requirement that solvent emissions are limited to comply
with environmental legislation and minimise costs.
Control Strategy Level 2
During development it has been identified that three
different parameters have a significant impact on the level
of impurity A being generated. They are:
&
&
&

CPP1 = Temperature
CPP2 = pH
CPP3 = Reaction End-point

Control Strategy Level 3

These parameters were studied extensively by Design of
Experiment (DOE) to ensure the Design Space boundary is
known. Measurement technologies proposed for these
parameters are:
&
&
&

CPP1: On-line temperature sensor

CPP2: On-line pH sensor
CPP3: Reaction end-point determination

The process model is a multivariate model incorporating

the measurements from the three different technologies.
Solvent limits are specified, and an end of line solvent
recovery plant is installed, to meet local authority limits,
and business cost drivers.
Near Infrared (NIR) measurement technology is applied
to control the reaction end-point.
The controls to ensure the CQA (impurity A) and solvent
emissions are integrated into a control model, taking
information from the NIR, temperature and pH sensors, as
well as monitoring solvent emission level. Information at
this level will also include the frequency of testing,
monitoring, sampling, and calibration.

Overall Presentation of the Control Strategy

The objective and requirements for control of the CQA
should be presented. The relevant control points for
reaction end-point, temperature and pH should be presented

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J Pharm Innov (2008) 3:95104

demonstrating that impurity A will meet the specification in

the finished product.
Details of the process and control model are given to
demonstrate how the process parameters are controlled.
This will cover how the input from the pH sensor,
temperature sensor and the NIR are combined in a model
and the output used to control the temperature of the reactor
pH adjustment and reaction end-point, and so predict the
level of impurity A.
Case Study Example 2
For simplicity and clarity only two quality attributes of the
product will be considered, one patient-related, the other
business-related. (Reference should be made to Fig. 2.).

of certain process impurities. The level of these oxidative

degradants in the dosage form is a CQA. There is a
business requirement that the cost of the overall process is
minimized.
Control Strategy Level 2
The process is reviewed to determine which material and
component attributes and process parameters must be
controlled. For the oxidative degradants there may be a
number of points in the process at which control might be
required, including:
&
&

Control Strategy Level 1

&
In this hypothetical example the product is a small molecule
drug presented as an injection dosage form - a liquid in a
vial - where the drug substance is susceptible to metalcatalysed oxidative degradation, enhanced by the presence

&
&

metal content of the starting materials for the synthesis

of the drug substance
metal content of the solvents and reagents used in the
synthesis of the drug substance
reaction conditions to minimise formation or ensure
removal of process impurities
use of non-metallic product contact materials in the
process
metal content of the excipients used in the drug product
Patient

Drug Substance Manufacture:

Control of
Process
Impurities

2
3
Patient

Business

Business

Control
of Cost

Online analysers monitor oxidative

impurities; Operate process at
optimum region within design space

1
2

Starting Material 1

Control of
Metal
Content

Reaction 1

Reaction 2

Reaction 3

Crystallisation

Starting Material 2

Test Methods and

Specifications

Starting Material 3
Starting Material 4

Patient

Drug Product Manufacture:

1
2

Patient

Finished Product
CQAs and Business
Requirements

Business

Business

Control of
Oxygen
Content

1
2

SOP: discard vials where oxygen

absorbed into product through
tubing during line stoppages

1
2
3

Control of
Metal
Content
Test Methods and
Specifications

Excipient 1

Formulation

Filling

Packaging

Excipient 2
Patient

Excipient 3
Nitrogen

Fig. 2 Control strategy example

Business

1
2

Control of
Oxygen
Content

Online Headspace Analyser

Finished
Injection

Patient

Business

Impurities:
Oxidative
Degradants

Cost

J Pharm Innov (2008) 3:95104

&
&
&

absorption of oxygen by the liquid product held in

filling lines etc.
oxygen content of headspace in vials
container-closure integrity to avoid oxygen ingress

103

filling line stoppages, and nitrogen sparging and purging is

used to minimize the oxygen content of the liquid and vial
headspace.
Control Strategy Level 3

In this example, based on the product and process

knowledge gained during development of the product, the
company has determined that control of several of these
factors is necessary to assure that the level of oxidative
degradants in the finished product is below the maximum
allowable levels.
A combination of process design and procedural controls
is employed to ensure the use of non-metallic contact
materials, such as glass-lined process vessels. Low oxygen
permeable tubing is used for the manufacturing process.
To control the metal content of the starting materials and
reagents the company decided to apply specifications and
test the materials identified through risk assessment as
providing the greatest risk to the product - starting materials
1 and 2 and excipient 1. The company considered the
specifications for the starting materials and decided to apply
tight specifications for certain attributes of starting materials 1 and 2 to avoid the need for an additional downstream
processing step to reduce process impurities.
This, however, has limited the choice of suppliers of
these starting materials who can meet the specifications. An
alternative strategy, in which wider specifications for these
materials would be applied and a downstream purification
step introduced, was rejected following a risk assessment
that concluded that the potential to form a genotoxic
impurity was greater and risk mitigation would be
considerably more expensive.
Product development knowledge and prior knowledge
had shown that control of reaction 2 was not critical to the
formation of the relevant process impurities for this CQA.
Although the company considered using traditional timebased end-points to control reaction 3 for the drug
substance manufacture it decided to develop a Design
Space and adopt a Control Strategy in which the reaction
conditions are adjusted to keep process impurities below
specified limits. This is achieved through the use of online
sensors and process analysers to monitor the process
conditions and formation of intermediates, feeding the data
into a process model to enable feedback control of reaction
temperatures and the addition of starting material 4, and to
ensure that the process operates within the design space.
This strategy had the advantage that the business
requirement to minimize the costs could be achieved by
adapting the process model to target operation within a
region of the Design Space that minimizes costs, while
ensuring the process impurities meet specifications. In the
drug product manufacturing process a further procedural
control is used to ensure certain vials are discarded after

The practical implementation of these controls includes:

&
&
&

The testing methods for the metal content of starting

materials, reagents and excipients
The online sensors and analysers to monitor reaction
conditions and their associated process models and
control systems
The SOP for actions to be taken after stoppages of the
filling line

The company identified Fourier Transform Infrared

(FTIR) spectroscopy as an appropriate analyzer technology
to monitor reaction 3. The proposed definition for a Control
Strategy from ICH Q10 also includes consideration of the
frequency of monitoring and control. The company
determined that collecting FTIR spectra every 5 minutes
during the 7 hours reaction 3 is run was sufficient to
monitor the progress of the reaction and adjust process
conditions as necessary.
The consequences of failures were also considered:
&
&
&

Can the failure be detected?

Can the effect of the failure be reversed?
What redundancy is required to reduce risks to tolerable
levels?

Risk assessment concluded that the nitrogen purge is a

critical processing step and failure would be difficult to detect.
The company therefore decided to mitigate this risk by online
monitoring of the headspace for each vial so that unacceptable
vials are identified and rejected. A further risk assessment
considered the impact of the failure of this additional control
and identified ways of mitigating this risk.
The selection and combination of these controls, applied
throughout the manufacturing process ensures that the
oxidative degradants will be at an acceptable level in the
finished injection. The Control Strategy is illustrated in
Fig. 2.

References
1. Product Quality Lifecycle Implementation: Practical Approach to
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104

4.

5.

6.

7.

8.

9.
10.

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