Bringing in biologics

The success of the CMC pilot for conventional drugs has prompted CDER to launch a similar initiative for biotechnology submissions. FDA announced the program in July 2008, calling for manufacturers to voluntarily submit CMC information in an Expanded Change Protocol (ECP) that describes the implementation of QbD and risk-management approaches for large molecules. OPS's Office of Biotechnology Products (OBP) is managing the pilot, which accepts original NDAs and biologic license applications as well as supplements.

The stated aims of the OBP pilot are to define clinically relevant attributes for complex products and link these approaches to the manufacturing process. Although many QbD principles apply equally to small molecules and to biologics, assessing relevant attributes is "a much greater challenge for complex pharmaceuticals," states FDA (1). Manufacturers have used comparability protocols to describe the specific tests and acceptance criteria that can ensure that a single manufacturing change will not produce negative effects. ECPs will describe QbD approaches and critical quality attributes as applied more broadly to multiple unit operations. As with drugs, QbD approaches for biologics aim to reduce process variability and to produce consistent therapies that meet quality attributes related to the product's efficacy and safety. This task is more difficult for biotechnology products because they are hard to characterize, and their manufacturing processes are more complex and variable.

That information should help the regulators implement a QbD, risk-based approach for complex products and to develop guidance for industry. As with the CMC pilot for drugs, manufacturers that adopt quality and risk-based approaches may gain leeway to make manufacturing-process changes without submitting postapproval manufacturing supplements.

Modifying early studies

Another FDA effort to establish appropriate oversight of drug manufacturing and quality-control methods involves modifying certain requirements for producing test therapies used in Phase I clinical trials. As part of its campaign to encourage innovative drug development, FDA proposed a new policy two years ago to exempt investigational drugs for early studies from certain GMP regulations. The agency withdrew that proposal, however, in the face of objections that the change could jeopardize the health and safety of participants in clinical trials. Since then, FDA has reviewed those comments and devised a new, more clearly articulated final rule.

The new policy, which took effect in September 2008, explains more clearly that FDA is modifying only manufacturing requirements that are not relevant for producing materials for early clinical trials (2). The agency has not changed policies designed to ensure drug quality during studies of large numbers of patients or during commercial production. Instead, the rule drops the requirement of a fully validated manufacturing process (including rotation of stock for drug-product containers) for products made for use in Phase I trials and the requirement for separate packaging and production areas.

The main beneficiaries of the policy are expected to be research laboratories and clinics that conduct investigatorinitiated studies. Some biotechnology companies might find the new policy helpful in producing small quantities of costly therapies because the rule applies to vaccines, recombinant biopharmaceuticals, in vivo diagnostics, blood products, and gene therapies.

But most drug and biotechnology manufacturers that enter Phase I studies with the expectation of moving on to Phase II and III trials are expected to meet GMP standards even when producing initial clinical supplies. Pharmaceutical companies want to ensure that all procedures are in place for future scale-up to larger trials—where test products must meet GMP requirements —and for eventual commercial production. Moreover, study sponsors want to avoid questions about the validity of data from a Phase I study that result from complaints that the test drug was not produced by a well-controlled, reproducible process.

In general, FDA leaves it to manufacturers to determine whether it makes sense in their particular case to produce Phase I drugs without fully complying with Part 211 regulations. Even manufacturers that decide to drop certain irrelevant manufacturing procedures are still responsible for ensuring the quality and safety of their investigational drugs. And FDA emphasizes that it always retains the right to halt a clinical trial if it finds that a test drug fails to meet quality standards.

To avoid such problems, FDA also issued a companion guidance with recommendations for establishing appropriate quality-control procedures for meeting GMP requirements for clinical supplies. The guidance emphasizes that manufacturers of test products should have well-defined written procedures, an adequately controlled manufacturing system, and accurate records from product testing and manufacture. Anyone producing even small quantities of a drug should conduct a comprehensive and systematic evaluation of the manufacturing setting (i.e., equipment, process, personnel, and materials) to identify and eliminate potential hazards. Small-scale operations may do this efficiently by using disposable equipment and prepackaged materials that reduce the chances of contamination. Using contract or shared manufacturing facilities and testing laboratories also may be helpful.

Jill Wechsler is Pharmaceutical Technology's Washington editor, 7715 Rocton Ave., Chevy Chase, MD 20815, tel. 301.656.4634, jwechsler@advanstar.com

Reference

1 FDA, "Submission of Quality Information for Biotechnology Products in the Office of Biotechnology Products; Notice of Pilot Program," Fed. Regist. 73 (128), 37973 (July 2, 2008).

2. FDA, "Current Good Manufacturing Practice and Investigational New Drugs Intended for Use in Clinical Trials," Fed. Regist. 73 (136), 40453–40462 (July 15, 2008).