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Quality Risk Management

According to ASTM E2500:


Standard Guide for Specification, Design and Verification for
Pharmaceutical and Biopharmaceutical Manufacturing Systems and
Equipment
Brian Evald Andreasen, May 2009

BnAn@nnepharmaplan.com
Direct telephone: +4530751381
Agendaen

Fra indbydelsen:
• På mødet vil Brian Andreasen fra NNE Pharmaplan
fortælle om hans erfaringer med at implementere
standarden hos Pfizer globalt.

• Han vil give et overblik over indholdet i standarden


sammenholdt med traditionel kvalificering,

• og der vil blive givet konkrete eksempler på Risk


Management og Verifikation.

Slide 2
NNE Pharmaplan, my workplace
• Over 80 years of experience in the pharma and biotech industries

• Spanned over 3 continents across Europe, North America and Asia

• Workforce 2008: More than 1500

• Turnover 2007: DKK 1.444M, €194M, $249M

• ISO 9001 certified since 1995; certified worldwide in 2008

• ISO 14001 certified since 2003

Slide 3
Global reach - local knowledge

Slide 4
Where is the best Quality?

David Dolgin, Abbott


2008 Washington ASTM C&Q

Traditional New Risk Based


C&Q Verification
Approach Slide 5
The benefits from E2500 are
incredible……

Moves away from ‘paper quality’ and rigid


documentation practices -
to product quality and patient safety.

u e
Faster project execution
tr
Focus on patient safety
l y
ab
Significantly reduces documentation
Enhanced process understanding

o b
Saves time and resources

pr
Higher production yield (OEE)
Improved quality at less costs - better use of expertise

n d
Compliance with Health Authorities expectations

a
to risk based approach


Thus, improved quality, major cost reduction (above 40%), faster to market and
longer time to take the right decisions for investments.

Slide 6
The Pfizer case

Pfizer is the largest pharmaceutical company in the world

They had with support from NP implemented a risk based verification


system globally in the company according to the new ASTM E2500
standard.
(Before Pfizer had a traditional C&Q approach according to ISPE C&Q
guide Vol 5 similar to NN)

•By adapting the new risk based approach…Pfizer expect to:

• save 40% of all expenses to Commissioning and Qualification


• Eliminate between 2 and 6 month of project execution time.
• Get improved quality level

Slide 7
ASTM!!!!
What is that….?
• Large voluntary standards development
organization

• Not-for-profit organization

• Established in 1898

• Purpose is to develop standards in response to


market needs

• Technical standards for materials, products,


systems, and services

• HQ in Philadelphia,
• Sub-offices in London, Mexico City &
Beijing

Slide 8
ASTM Committee E55

• Established Spring 2003

• Development of standardized nomenclature and


definitions of terms recommended practices, guides,
test methods, specifications, and performance
standards for the manufacture of pharmaceutical
products.

Slide 9
Issued Standards (Pharma) :
• E2363-06a Standard Terminology Relating to Process Analytical
Technology in the Pharmaceutical Industry

• E2474-06 Standard Practice for Pharmaceutical Process Design Utilizing


Process Analytical Technology

• E2500-07 Standard Guide for Specification, Design, and Verification of


Pharmaceutical and Biopharmaceutical Manufacturing Systems and
Equipment

• E2503-07 Standard Practice for Qualification of Basket and Paddle


Dissolution Apparatus

• E2537-08 Standard Guide for Application of Continuous Quality


Verification to Pharmaceutical and Biopharmaceutical Manufacturing

Slide 10
Work Items in Progress (E55.01)
• WK5930 Standard Practice for Risk Assessment and Risk Control as it Impacts the
Design, Development, and Operation of PAT Processes for Pharmaceutical
Manufacture (Gawayne Mahboubian Jones)

• WK5935 Standard Guide to Process Understanding (Jean Marie Geoffroy)

• WK9192 Standard Practice/Guide for the Application of Continuous processing in the


Pharmaceutical Industry (Trevor Page)

• WK15151 Standard Guide on Sampling (Joep Timmermans)

• WK9182 Standard Guide for Verification of Process Analytical Technology (PAT)


Control Systems (Bruce Davis)

• WK9191 Standard Guide for Multivariate Data Analysis Related to Process Analytical
Technology (Chun Cai)

• WK13538 Standard Practice for Identification of Critical Attributes of Raw Materials in


Pharmaceutical Industry (Marino Nebuloni) WK11898 Standard Practice for Real-time
Release of Pharmaceutical Water for the Total Organic Carbon Attribute (Rich Godec)

• WK15778 Guide for Science-based and Risk-based Cleaning Process Development and
Validation (Andrew Walsh)

• WK16888 Guide for Validation of PAT Methods (Jim Rydzak)


Slide 11
Essence of the E2500

The scope and extent of quality risk


management for
specification, design, and verification
activities and documentation should be
based on the risk to product quality
and patient safety.

The level of effort, formality and


documentation of the quality risk
management process should be
commensurate with the
level of risk.

Slide 12
Important Terms
Critical Quality Attributes (CQA)
A Critical Quality Attribute is defined as 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)

Dissolution
Disintegration
Apperance
Hardness
Content Slide 13
uniformity
Important Terms
Critical Process Parameters

A Critical Process Parameter is defined as a


process parameter whose variability has an
impact on a CQA and therefore should be
dP Time
monitored or controlled to ensure the process
Speed parameters produces the desired quality (ICH
Pressure
Q8)
Velocity
Conc
pH
Pressure Pressure

Pressure
Velocity

Pressure

Flow
pH
Dissolution Time
Disintegration
Apperance
Hardness
Content Slide 14
uniformity
Important Terms
Critical Aspects Critical Aspects are defined as
functions, features, abilities, and
performance or characteristics
necessary for the manufacturing
process and systems to ensure
consistent product quality and patient
Sanitary safety (ASTM E-2500-07)
design

Parameter alarms Non turbulent


agitor Filter integrity

Vision system for


monitoring
Dissolution
Disintegration
Apperance
Hardness
Batch documentation
Content Calibration Slide 15
Slide 15
uniformity
GMP
Important Terms
Subject Matter Experts (SME)

SME is defined by ASTM as:


• Individuals with specific expertise and
responsibility in a particular area or field (for
example, quality unit, engineering, automation,
development, operations, and so forth).

Slide 16
The SME role & responsibilities

From E2500

• Subject matter experts should take the lead role in the


verification of manufacturing systems as appropriate within
their area of expertise and responsibility.

• Subject matter expert responsibilities include planning and


defining verification strategies, defining acceptance criteria,
selection of appropriate test methods, execution of
verification tests, and reviewing results.

Slide 17
Risk Based Approach
The old way

Impact Assessment – (systems & Components)

• Evaluating design for impacting the product quality, but no


evaluation of the level of potential risk for product and
patient.
• No Risk Mitigation
• System and component level focused
• Component ImpactC Assessment is conducted after design
NC
development.
Direct Impact

Indirect Impact

Slide 18
Risk Based Approach
The new way
Quality Risk Management – Risk 1 ..

Ongoing and iterative Risk Management


process

From CQA and CPP are defined to


………handover for operation.

Slide 19
Risk Based Approach
The new way
Quality Risk Management – Risk 1 ..

• Definition of CQA, CPP & Critical aspects


• Risk ranking
• Risk mitigation:
¾ Design solutions
¾ Control strategy
¾Design Review
¾ Suppliers selection
¾ SME allocation
¾ Test
¾ Documentation
¾ etc

Slide 20
Quality Risk Management
Determination of Critical Aspects

Risk 1 ..

Critical Aspects must be identified during the risk
Management process.
Critical Aspects are derived directly from CQA and the
general GMP compliance issues.
Critical Aspects are subject to risk assessment and
risk mitigation; if possible and Verification testing.

Slide 21
Quality Risk Management
Identifying potential Risk
Customized

New New Customized


Vendor technology
Well known
Well known technology
vendor
Bad
Vendor
Exact
Customized Simple Copy
Complex process Equipment Equipment
and
many interfaces Critical Process
Parameter
Unstable process

Manual
Equipment Slide 22
Quality Risk Management
Risk Mitigation – Safe design solutions & Control strategy

Sanitary issue:
Removal of pumps,
by using gravity

PAT PAT
Monitoring Monitoring

Risk 1 ..
Equipment …

Monitoring Manual
Monitoring

Slide
Slide 23
23
Quality Risk Management
Risk Mitigation - Vendor Assessment Risk 1 ..

Interfaces
to other disciplines
Custom made
or vendors ?
or bulk?

New Technology?

Documentation?
Experienced
employee? Slide 24
Quality Risk Management
Risk Mitigation -Design Review (DR)
The DR is an important part of the risk management
process, and DR must be focused on the risk
aspects:

• Design meets the mitigated unacceptable risk Risk 1


√ ..

derived from the risk assessment process. … √




• Planned Verification testing and acceptance criteria √
are sufficient and commensurate to level of √
quality risk.



• Design Meets relevant Critical aspects and
ensure that Critical Process Parameters can be
controlled to the desired level

• The Critical Quality Attributes (CQA) can be


ensured by the proposed design

Slide 25
Quality Risk Management
Use of Vendors test results etc

Vendors test documentation may be used as part of the verification


documentation, if the vendor is assessed, and there is evidence of:

• An acceptable vendor quality system,

• Vendor technical capability

• Vendor application of GEP such that information obtained from


the vendor will be accurate and suitable to meet the purpose of
verification.

If inadequacies are found then we have to mitigate potential risks


by applying specific, targeted, additional verification checks or
other controls rather than repeating vendor activities and
replicating vendor documentation.

Slide 26
Quality Risk Management
Test- planning
Mapping
CQA & CPP

Critical Aspects
&
Risk Assessment

Risk
Mitigation

Planning
Verification

Commensurate Intensive test


with the Vendor test Vendor test SME participation
level of risk SME Approval SME surveillance & SME approval
Slide 27
Graphic Model
Issued by ASTM

Slide 28
Quality Risk Management Process

Risk
Mitigation Design
CQA Critical Risk + Vendor SME
+ Verification
CPP aspects Ranking DER issues Involve-
New
ranking issues ment

Link to
illustration

Slide 29
Risk Mitigation

Slide 30
Quality activities commensurate with the
level of risk.

Slide 31
Pfizer ASTM E2500 Transformation
Pfizer Case
ASTM E2500 Transformation
• Transformation from C&Q to
Verification based on ASTM
E2500

• Part of a Lean project to


streamline current practices
and enable more production
capacity for the same
investment capital
Pfizer C&Q
• Transformation project done
by global Engineering &
Quality team together with
NNE Pharmplan

• 2 project phases:
• Gap mapping & Scope
Setting
• Document writing, review
and approval
• Pilot implementation ongoing Pfizer Verification

Slide 33
Pfizer Case
ASTM E2500 Transformation - 2
• Combines E2500 with Quality by
Design principles and Lean
methods

• Integrates
• Engineering
• Automation
• Quality
• Maintenance etc.

• Based on Quality by Design


Quality Risk Management
principles (ICH Q8, Q9, Q10)

• Applies to new and legacy


manufacturing systems

• Global Engineering Rollout on all


sites is ongoing
Pfizer Verification

Slide 34
Quality by Design in NNE Pharmaplan:
Transform C&Q to ASTM Verification
Client
• Pfizer Client Case 2008
• Global Engineering - for global use on all
manufacturing sites

Service
• Transformation of Pfizer C&Q program to
the ASTM E2500 standard for
Verification, for use globally
• Combined with a Pfizer Lean Program to
streamline current practices and get
more value of investments – both on
money and time
• 3 months delivery time Dissolution
Disintegration
• 5 consultants in NP Consulting Denmark Apperance
and USA plus global roll-out assistance Hardness
Content uniformity

Deliverables
• Full update of existing procedures to
ensure the harvesting of benefits of the Customer Quote:
Verification approach instead of the ”We selected NNE Pharmaplan for the work
traditional validation approach of
Commissioning and Qualification because these guys really understands
the QbD principles in practice.
What’s in it You guys really got it!”
• Faster and more cost-effective
verification compared to traditional ASTM E2500 Standard Guide
’validation’ for Specification, Design, and
Verification of Pharmaceutical
and Biopharmaceutical
Manufacturing Systems and
Equipment
Slide 35
C&Q vs Verification Opportunities

100% #1 Fewer systems in Quality Unit scope


#2 Leverage GEP & Subject Matter Experts (Less details)
#3 Leverage Supplier Documentation
#4 Avoid repetition of tests etc.
#5 Reduce Periodic Review Scope
#6 Reduce number of docs retained etc.
#7 Flexibility and Scalability
#8 Other
C&Q Cost

Verification Cost

Slide 36
1st Generation – and the next:
Face the Learning Curve
• Every new paradigm has its learning curve
• 1st Generation is not always right
• Example: From the Horse Cap to the 1st Generation Taxi

1st Generation Taxi 2nd Generation Taxi

Slide 37
BnAn@nnepharmaplan.com
Direct telephone: +4530751381
Slide 38
Back up slides

Slide 39
A Brief Validation History
First FDA Validation Guideline
1987
• “Process validation is
establishing
documented
evidence which provides
a high degree of assurance
that a specific process will
consistently produce a
product meeting its pre-
determined
specifications and
quality
characteristics” GUIDELINE ON GENERAL PRINCIPLES OF
PROCESS VALIDATION
MAY, 1987 FDA CDER, CBER, CDRH

Slide 41
ISPE C&Q Baseline Guide 2001

• “The application of this C&Q


process helps to ensure that
the appropriate resources are
applied to those systems and
components within a facility
that have the potential
to affect product
quality; and secondly,
provides the rationale to reduce
the scope of work for the
qualification of the plant, while
still ensuring compliance for the
product(s).”

• Commissioning (i.e. GEP)


• Qualification (i.e. QA)
ISPE Baseline Engineering Guide
Commissioning & Qualification
(Baseline Guide 5) 2001 Slide 42
New FDA Process Validation Guide
DRAFT Nov. 2008
• “Effective process validation contributes
significantly to assuring drug quality.
• The basic principle of quality assurance is
that a drug should be produced that is
fit for its intended use

• This principle incorporates the


understanding that the following
conditions exist:
• Quality, safety, and efficacy are
designed or built into the product.
• Quality cannot be adequately assured AFT
merely by in-process and finished- D R
product inspection or testing.
• Each step of a manufacturing process
is controlled to assure that the
finished product meets all design
characteristics and quality attributes
including specifications. “
Stage 1 – Process Design
Stage 2 – Process Qualification
Stage 3 – Continued Process
Verification Slide 43
C&Q vs. ASTM E2500
Engineering Change Management

QA Change Control

Old C&Q Design


Development
Enhanced Commissioning PQ Process
Design Review Validation

IQ & OQ

Engineering Change Management QA Change


Control

New Verification
Design
Risk Based Approach Development
ASTM E2500
Design Review Commissioning PT Process
Validation

Performance
Testing
Slide 44
Verification overview
From ISPE’s draft of coming new Verification guideline

Slide 45
Planning Verification

From E-2500:

• The acceptance criteria and verification strategy should be documented in


appropriate verification plans.

• The verification plan should define what constitutes acceptable documentation


of subsequent verification activities.

• The verification plan should be developed and approved by subject


matter experts.

• Verification plans for systems containing critical aspects should be approved


by the quality unit.

Slide 46
Graphic model
NNE Pharmaplans model

Slide 47
NNE Pharmaplan is involved in the
new Pharma Standard Settings
• NNE Pharmaplan is closely involved in the
setting of the new standards of the
pharmaceutical industry
• ASTM Committee E55 on Manufacture of
Pharmaceutical Products
• ISPE
• PDA
• We have participated in setting the new
standards of the pharmaceutical industry
in ISA, GAMP, ISPE, PDA and ASTM for 20
years

• We call it ”More than Engineering…”

Slide 48