A favourable impact of implementing the new International Conference on Harmonization of Technical Requirements for Registration
of Pharmaceuticals for Human Use (ICH) quality principles and process analytical technology (PAT) to promote enhancements
of manufacturing efficiency and quality is a strategic goal for both regulatory authorities and the industry.1–3
Both industry and the public can benefit from ICH Q8 (pharmaceutical development), ICH Q9 (quality risk management [QRM]),
and PAT principles and strategies as they foster quality by design (QbD) approaches during development of the process, and
provide a platform for 'continuous improvement'.
Demonstrating adherence to modern science- and risk-based design, manufacturing, and modern control principles and strategies
may allow authorities to adjust the level of regulatory oversight to the level of science-based' process understanding' and
risk mitigation.
To support public discussion within the industry, and between industry and regulators leading towards this goal, European
Federation of Pharmaceutical Industries Association (EFPIA) representatives have developed a discussion document (common technical
document [CTD] section called 'Mock P.2'). The document discusses Examplain, a fictitious tablet product, which exemplifies
the role of QRM and PAT to achieve QbD. This paper summarizes the main features of the Mock P.2 document. Mock P.2 aims to:
- Promote discussion and learning between companies, and between EFPIA and regulatory authority reviewers and inspectors.
- Facilitate the scientific and regulatory dialogue between industry and regulatory authorities on the presentation of enhanced
product and process understanding in regulatory dossiers.
- Exemplify application of QRM principles (ICH Q9) during the development process.
- Illustrating PAT-based manufacturing and process control strategies that enable 'continuous quality verification', and ultimately
'real-time release'.
- Demonstrating how application of QbD (ICH Q8) principles can be used to establish process understanding and the design space.
The design space is defined as the multidimensional combination and interaction of input variables (for example, material
attributes) and process parameters that have been demonstrated to provide assurance of quality.1 Working in the design space is not considered as a change. Movement out of the design space is considered to be a change
and would normally initiate a regulatory post approval change process. Design space is proposed by the applicant and is subject
to regulatory assessment and approval.
It is important to understand that the discussion document illustrates just one of many possible approaches to achieve the
ultimate goal of QbD. Therefore, the document must not be taken as 'a standard recipe' for product development nor as a complete
example for an actual submission document.
Products and manufacturing processes should be designed to manage variation. Formulation and process design in combination
with risk management principles should be applied to ensure QbD is achieved during development and manufacture, yielding good
understanding and control of variation. Manufacturing processes based on QbD are a means to mitigate the risk of variable
product unit quality. Use of design space (ICH Q8 ), QRM (ICH Q9), and PAT principles, tools and practices, enables QbD to
achieve the desired state.
The Mock P.2 submission
The Mock P.2 document gives examples of how quality can be built-in during formulation and process development. It includes
the following concepts:
- The use of models and algorithms.
- The use of in-line and at-line tools.
- Using prediction models to establish the design space.
- Design space not requiring 'edge of failure' — a process parameter value that, if exceeded, means adverse effect on the process
output or product quality.
- Linking control strategy to design space.
- The use of QRM principles.
In particular, it describes how enhancement of process understanding can be applied using prior knowledge and iterative application
of QRM principles based on the target product profile during the design and development process.
The document is complemented by a 'mock' section P.3.3 excerpt outlining the process control strategy proposed for routine
manufacture, which is based on the knowledge and understanding available and linked to a QRM review of all information available.