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US FDA: Request for Quality Metrics Presented by Eoin Hanley 4 July, 2016

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Page 1: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

US FDA: Request for Quality Metrics

Presented by Eoin Hanley

4 July, 2016

Page 2: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 2 © PharmOut 2015

What we will cover in this session

Why we use quality metrics

Why the US FDA want to look at quality metrics

What the US FDA intend to look

Proposed Optional Metrics

Page 3: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 3 © PharmOut 2015

Guidance in draft

• Draft issued in last week of July

• Comments & suggestions within 60 days

• Based on their mission to protect and promote public health

Metrics:

1. Objective

2. Subject to inspection under section 704 of FD&C Act

3. Valuable in assessing the overall state of quality of product/process/PQS etc

4. Avoid any undue reporting burden

Page 4: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 4 © PharmOut 2015

Quality Metrics

Why do “we” use Quality Metrics?

Page 5: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 5 © PharmOut 2015

Why do “we” use quality metrics?

Monitor Quality Control Systems

Process Validation &

lifecycle

Pharmaceutical Quality Systems

Monitor production processes

Indicators for Continuous

Improvement

Page 6: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 6 © PharmOut 2015

Why do the US FDA want to look quality metrics?

• Help develop compliance and inspection policies & practices

• Risk–based inspection scheduling

• Ability to predict/mitigate future drug shortages

• Support its understanding of the inherent risks

• Resources & help direct the inspections

• Encourage state-of-the-art, innovative PQS

• They have the authority to request records and information by law

Highly controlled manufacturing processes have the potential to be inspected less often

Page 7: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 7 © PharmOut 2015

Risk-based schedule of inspections

• The compliance history

• The record, history and nature of recalls

• The inherent risk of the drug manufacturing processes

• Inspection frequency and history

• Inspections by foreign governments/agencies

• Any other criteria deemed necessary

The risks posed by establishments are based on:

Page 8: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 8 © PharmOut 2015

What data do the US FDA want?

• Manufacture, preparation propagation, compounding or processing of a finished dosage forms of covered drug products or APIs used in the manufacture of covered drug products

• Request would not apply to medical gasses, PET, blood & blood components for transfusion, vaccines, cell & gene therapy products, allergenic extracts, human cells, non-recombinant versions of plasma derived products etc.

• Also encouraged to submit quality metrics data for certain foreign establishments

Page 9: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 9 © PharmOut 2015

What data do the US FDA want?

• The requests for data would include (but are not limited to:

• Contract laboratories

• Contract sterilisers

• Contract packagers

• Or engaged in manufacture, preparation, propagation, compounding or processing etc

• At this time, does not include excipient or container/ closure manufacturers

• One Report for each Finished Dosage Form and one for each API of a covered drug product with metrics

• Quality Control Unit best positioned to compile Reports

As a Contract Giver, you do not delegate your

regulatory responsibilities!

Page 10: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 10 © PharmOut 2015

Quality Metrics

What quality metrics do your vendors supply you with?

Page 11: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 11 © PharmOut 2015

What will the US FDA do with the data?

Recognise the value of quality metrics

Use the data in context with other sources of quality data

Not intended to be all-inclusive set of quality metrics that the US FDA consider useful for assessment

Failure to produce records and information within a reasonable timeframe/refusal to permit access to a record will mean that drugs from the facility may be deemed adulterated

Page 12: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 12 © PharmOut 2015

Where will the quality metrics come from?

• Records associated with a Process Validation Lifecycle and PQS Assessment

• Understand the sources of variation

• Detect the presence and degree of variation

• Understand the impact of variation on process/product

• Control the variation in a manner commensurate with the risk to process/product

• Throughout the lifecycle-including changes

• Evaluation of the state of control

Page 13: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 13 © PharmOut 2015

Where will the quality metrics come from?

Annual Product Reviews/PQRs

Process trends and quality of incoming materials, in-process materials and FPs

Statistically trended by trained personnel

Verification that quality attributes are being controlled

Review a representative number of batches

Facility, systems and equipment status periodically assessed

Continuous/real-time metrics

Page 14: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 14 © PharmOut 2015

What the US FDA intend to look at

• Evaluate whether data reported is consistent with their understanding

• Evaluate how best to interpret and use the metrics:

• Compare metrics for different products?

• Compare same product at different sites?

• A facility trended over time?

• All facilities/subset making the same dosage form or same drug against each other?

• Manufacturing complexity? i.e. biologicals

• The US FDA do not intend to publicly disclose quality metric data submissions

Page 15: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 15 © PharmOut 2015

What the US FDA intend to calculate

= 1 – x, where x = the # of specification-related rejected lots in a timeframe ÷ # of lots attempted in the same timeframe

= # of complaints received for the product ÷ the total # of lots of the product released in the same timeframe

Lot Acceptance Rate

Product Quality Complaint Rate

Page 16: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 16 © PharmOut 2015

What the US FDA intend to calculate

= the # of OOS test results for the FP invalidated ÷ the total # of OOS ÷ the total # of tests performed in the same timeframe

= # of APR/PQRs completed within 30 days of annual due date ÷ # of products produced at the facility

Invalidated OOS Rate

APR or PQR on Time Rate

Page 17: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 17 © PharmOut 2015

Additional request for public comment

Opportunity to submit additional optional metrics as evidence of robustness and a commitment to quality?

May merit a reduction in inspection frequency?

Measures of quality culture? Senior Management engagement?

3 Optional Metrics proposed (next few slides) but US FDA also request alternative approaches

Page 18: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 18 © PharmOut 2015

Proposed Optional Metric 1

• CAPA Effectiveness

• Strong indicator of a robust quality culture

• Continual Improvement-prevent the initial occurrence or recurrence of an undesirable situation

• Weak systems: personnel re-training

• Strong systems: re-design/re-development of the process

What % of your corrective actions involved re-training of personnel (i.e. a root cause of the deviation is lack of adequate training)?

Page 19: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 19 © PharmOut 2015

Proposed Optional Metric 2

• Process Capability/Performance

• Statistical Process Control-understand variability

• Statistician/person with adequate training

• Data Collection Plan

• Methods & Procedures

• Knowledge during scale-up & manufacturing

• Control Strategy

• Evaluate process stability/capability

• Must be appropriate/meaningful

• Science and risk-based QRM

Page 20: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 20 © PharmOut 2015

Proposed Optional Metric 3

A “YES” or “NO” value of whether there is a process capability or performance index for each CQA as part of the APR/PQR

A “YES” or “NO” value of whether there is a policy of requiring a CAPA at some lower process capability or performance index

If a “YES” to the above question – what is the process capability or performance index that triggers a CAPA?

If “NO” to the above question – please do not respond.

Page 21: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 21 © PharmOut 2015

What the US FDA want to see

# of lots attempted of the product

# of specification-related rejectedlots of the product, rejected during or after manufacturing

# of attempted lots pending disposition for more than 30 days

# of OOS results for the product including stability testing

# of lot release & stability tests conducted for the product

# of OOS results for lot release & stability tests for the product which are invalidated due to lab error

Page 22: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 22 © PharmOut 2015

What the US FDA want to see

# of product quality complaintsreceived for the product

# of lots attempted which are released for distribution or for the next stage of manufacturing

If the associated APRs or PQRs were completed within 30 days of annual due date for the product

The number of APRs or PQRs required for the product

Page 23: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 23 © PharmOut 2015

How to report quality data

• Submit data for a 1 year period after the Agency request

• Reports to be submitted within 60 days of the end date of the reporting period

• Data segregated in the report on a quarterly basis

• Appendix A describes the information that would be submitted through the Electronic Submissions Gateway

• US FDA also want additional information on:

• When to make additional requests for data

• Alternative approaches to data collection i.e. alignment with current APR/PQR timeframes

• Text fields for data explanation

Page 24: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 24 © PharmOut 2015

Other quality metrics?

Can you suggest other quality metrics that might be useful?

Page 25: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 25 © PharmOut 2015

Section recap?

Risk-based Inspections

Drug Shortages

Opportunity to provide feedback

Page 26: US FDA: Request for Quality Metrics · Where will the quality metrics come from? Annual Product Reviews/PQRs Process trends and quality of incoming materials, in-process materials

Slide 26 © PharmOut 2015

Thank you for your time.Questions?

Eoin Hanley

[email protected]

Technical Manager

www.pharmout.net