State of Control Over the

Lifecycle and Process

Validation (New and Legacy
Products)
Grace McNally
Branch Chief (acting),
Regulatory Policy and Collaboration Branch
FDA/CDER/Office of Compliance
 Agenda
 ICH Q10, FDA & EU
 State of Control and Process Performance and Product
Quality Monitoring (PP&PQM) and Process Validation
 Focus on Variation
 CGMP Regulations and PV Guidance
recommendations link to ICH Q10
 Milestones and Transitions in the PV Lifecycle
 Verifying Continuing State Of Control
 Data Analysis and Statistical Tools for PP&PQM
 PQS: Three Main Objectives
 A modern PQS assures quality over the drug
lifecycle
1. Achieve product realization, e.g., by effective
knowledge transfer from development to
commercial production
2. Establish and maintain a State of Control

3. Facilitate Continual Improvement

4
 ICH Q10, State of Control:
A condition in which the set of controls consistently provides assurance
of continued process performance and product quality.

FDA Guidance For Industry; Process

Validation: General Principles and EU Guide to GMP, Annex 15:
Practices
Process Validation:
Process Validation: Documented evidence that
collection and evaluation of the process, operated within
data, from the process established parameters, can
design phase throughout perform effectively and
production, which reproducibly to produce a
establishes scientific medicinal product meeting
evidence that a process is its predetermined
capable of consistently specifications and quality
delivering quality products. attributes.
 ICH Q10
Establish and Maintain a State of Control (1.5.2)
To develop and use effective monitoring and control systems for
process performance and product quality, thereby providing
assurance of continued suitability and capability of processes.

Facilitate Continual Improvement (1.5.3)

To identify and implement appropriate product quality
improvements, process improvements, variability reduction,
innovations, and pharmaceutical quality system enhancements,
thereby increasing the ability to fulfill a pharmaceutical
manufacturer’s own quality needs consistently. Quality risk
management can be useful for identifying and prioritizing areas for
continual improvement.
 ICH Q10, Section 3.2.1, PP&PQM

 (b) Provide the tools for measurement and analysis of

parameters and attributes identified in the control
strategy (e.g., data management and statistical tools).
 Tool don’t work themselves! Need personnel credentialed and qualified to
apply statistics to manufacturing data. Qualified to choose the tools
appropriate for the analysis, i.e., the question being asked.

 (c) Analyze parameters and attributes identified in the

control strategy to verify continued operation within a
state of control.
 Trending activities.
 Some examples of statistical tools

 From ICH Q9:

 Design of experiments
(DOE)
 Histograms
 Pareto charts
 Control charts
 Process capability analysis
There are many other tools
available.
 What about Standards?
Footnote in the FDA PV Guidance:

Some references that may be useful include the following:

ASTM E2281-03 “Standard Practice for Process and Measurement
Capability Indices”
ASTM E2500-07 “Standard Guide for Specification, Design, and
Verification of Pharmaceutical and Biopharmaceutical
Manufacturing Systems and Equipment,” and
ASTM E2709-09 “Standard Practice for Demonstrating Capability to
Comply with a Lot Acceptance Procedure.”

This is not a complete list of all useful references on this topic. Many
industry standards, books, and guides on these topics are available.
 ICH Q10, Section 3.2.1, PP&PQM

 (d) Identify sources of variation affecting process performance

and product quality for potential continual improvement
activities to reduce or control variation.
 Does this refer to common cause variability or special cause variability? Both! Need to
know your common cause variability. May want to reduce it. Also need to be able to
detect special cause and then correct it."

 (e) Include feedback on product quality from both internal and

external sources (e.g., complaints, product rejections,
nonconformances, recalls, deviations, audits and regulatory
inspections, and findings).
 Very valuable and a required practice but not proactive. It’s too late to increase the
product’s quality at this point!
 Annex 15 (2001) under Prospective
Validation

“Using this defined process (including specified

components) a series of batches of the final product
may be produced under routine conditions. In theory
the number of process runs carried out and
observations made should be sufficient to allow the
normal extent of variation and trends to be established
and to provide sufficient data for evaluation.
 Sources of Input Variability
How can these factors impact the output variability?

 Materials (APIs, Excipients, Process aids)

 Equipment
 Measurement Systems
 Procedures/Master Records
 Environment
 Operators
Analyze process performance and control batch-
to-batch variability!
 Opportunities for Variability
Reduction and Innovation
“Implement appropriate product quality
improvements, process improvements, variability
reduction, innovations and pharmaceutical quality
system enhancements”
[ICH Q10 ]

Intellectual growth should commence at birth and cease only at

death. Albert Einstein
 FDA PV Guidance
“We recommend that the manufacturer use
quantitative, statistical methods whenever
appropriate and feasible. Scrutiny of intra-batch
as well as inter-batch variation is part of a
comprehensive continued process verification
program under 21 CFR§ 211.180(e).”
 FDA CGMPS on process control,
variability and performance

Section 211.110(a)
Control procedures shall be established to monitor the output and to validate the
performance of those manufacturing processes that may be responsible for
causing variability in the characteristics of in-process material and the drug
product”

Section 211.110(b)
requires that in-process specifications “. . . shall be consistent with drug product final
specifications and shall be derived from previous acceptable process average and
process variability estimates where possible and determined by the application of
suitable statistical procedures where appropriate.”
 FDA CGMPS on periodic evaluation
and change
Firm must evaluate, at least annually, the quality standards of each
drug product to determine the need for changes in drug product
specifications or manufacturing or control procedures.
(211.180(e))
Why change specifications?
Why change a manufacturing procedure?
Why change a control procedure?

Some times to increase process efficiency.

Some times to correct a design flaw/problem that was not revealed during design
and process qualification.
Overall, to maintain a state of control based on new knowledge and increasing
process understanding!
 Milestones and Transitions
 Application or MA is approved - A Major Milestone!!
 May or may not include the initial demonstration of the
process at commercial scale. Depends on the type of drug,
type of process (e.g. is it considered a special or non-standard
process?), and review policies/guidance from the particular
regulator.
 Recognize that while a significant milestone has been
reached, the job is not done. Weave this philosophy through
PQS fabric

 A basis to begin commercial distribution of product

 Before commercial distribution, Initial commercial process
evaluation
 Recognition that initial commercial production provide first
picture of process control to which more understanding and
knowledge will be added.
 Milestones and Transitions
 Transition from Stage 2 to Stage 3 (FDA PV Guidance)

analogous to

Tech Transfer to Commercial Production (ICH Q10)

 Seek to understand and measure commercial process inherent

variability; its natural behavior when in control and not acted
upon by any special causes.
 Necessary to establish process control limits.
 Be circumspect, realistic and open-minded
 Move from uncertainty and estimates to certainty and knowledge
over time.
 ?
Certainty
Assumptions
Confidence
Estimates
Knowledge
Uncertainty
?
 FDA PV Guidance
Heightened sampling/ monitoring after
Stage 2
“We recommend continued monitoring and sampling of process parameters and
quality attributes at the level established during the process qualification stage
until sufficient data are available to generate significant
variability estimates. These estimates can provide the basis for
establishing levels and frequency of routine sampling and monitoring for the
particular product and process. Monitoring can then be adjusted to a
statistically appropriate and representative level. Process variability
should be periodically assessed and monitoring adjusted
accordingly.”
 FDA PV Guidance
Heightened sampling/ monitoring after
Stage 2
 Purpose of the recommendation?
 To establish the appropriate levels and frequency of routine
sampling and monitoring for that particular product and
process.

 Stepped down approach to monitoring, particularly for new

processes, or significantly changed processes, for which there
is little previous comparable experience.
 Statistical Control Charts
 Statistical control charts are used to monitor a process for
statistical control and are time plots with control limits added.
 Control limits are an estimate of the natural variability of the
process. Control limits are not specifications limits.

I-M R C ha r t o f In C o ntr o l O ut S pe c
U C L= 1 1 2 . 7 7
110
Individual V alue

105 105
_
X= 1 0 0 . 9 6
100

95 95

90 LC L= 8 9 . 1 6
1 6 11 16 21 26 31 36 41 46
O b s e r v a t io n

16
U C L= 1 4 .5 1
12
M oving Range

8
__
4 M R = 4.44

2
0 LC L= 0
1 6 11 16 21 26 31 36 41 46
O b s e r v a t io n
 CPV? CQV?
Continued? Continuous?
What does it all mean?
 Continuous Process Verification: An alternative approach to
process validation in which manufacturing process performance
is continuously monitored and evaluated (ICH Q8 –Glossary).

 Continued Process Verification – Third stage process validation

lifecycle after design and qualification. The goal is to continually
assure that the process remains in a state of control (the
validated state) during commercial manufacture. (FDA Guidance
on Process Validation)

 Continuous Quality Verification (CQV) as an approach to

process validation where manufacturing process (or supporting
utility system) performance is continuously monitored, evaluated
and adjusted (as necessary) (ASTM E2537).
 Process Performance & Product
Quality Monitoring
 Where do you start?
 What defines product quality?
 How are specifications set for raw materials, In- process, and finished
product

 More Questions
 What defines process performance?
 How are sources of variation identified, monitored, and controlled?
 What are the measurement tools?
 What analysis is being done?
 Can inferences be made about untested units? With what confidence
level?
 Is there a feedback mechanism?

 Use answers to determine best data collection methods and data analysis
tools.
 “It met specifications”
 Conclusions from sampling and testing are
probabilistic.

 Interplay between sample size, process variability,

confidence desired and probability.

 The outcome from conducting a single USP test cannot

be assumed for all the untested units in the batch.
 USP 33–NF 28 Reissue General Notices
 At times, compendial standards take on the character of statistical procedures,
with multiple units involved and perhaps a sequential procedural design to
allow the user to determine that the tested article meets or does not meet the
standard. The similarity to statistical procedures may seem to suggest
an intent to make inference to some larger group of units, but in all
cases, statements about whether the compendial standard is met apply
only to the units tested.

 Repeats, replicates, statistical rejection of outliers, or extrapolations of results

to larger populations, as well as the necessity and appropriate frequency of
batch testing, are neither specified nor proscribed by the compendia. First-
party (manufacturer), second-party (buyer), or third-party (regulator)
compliance testing may or may not require examination of additional
specimens, in accordance with predetermined guidelines or sampling
strategies
 Specifications and Batch
Release

FDA GMPS
21 CFR 211.165(d)
Acceptance criteria for the sampling and testing conducted by
the quality control unit shall be adequate to assure that
batches of drug products meet each appropriate
specification and appropriate statistical quality control
criteria as a condition for their approval and release. The
statistical quality control criteria shall include appropriate
acceptance levels and/or appropriate rejection levels.
 Acknowledgments

 Lynn Torbeck, Statistician, Torbeck and Assoc.

 Francis Godwin, FDA/CDER/OC
 Karthik Iyer, FDA/CDER/OC
 Tara Gooen, FDA/CDER/OC
 Rick Friedman, FDA/CDER/OC
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