Quality by design pilot extended by FDA

pharmafile | September 28, 2009 | News story | |  NHS, hc 

The US Food and Drug Administration has extended the deadline for groups wishing to take part in its quality-by-design pilot programme, set up last year, which allows applications for biotechnology-derived products to be filed with QbD information on chemistry, manufacturing and controls (CMC).

The agency has extended the deadline to request participation in the programme to 30 September, while submissions can be filed until 31 March, 2011.

QbD is a concept laid out by the International Conference on Harmonisation (ICH) in its most recent quality documents, including ICH Q8 on pharmaceutical development which sets out the concept of a 'design space', ICH Q9 on quality risk management and ICH Q10 on quality systems, which covers control strategies. Another forthcoming document, ICH Q11 on active substances, will also contain QbD elements.

The aim is to develop ways in which quality is built into products from the earliest stages of development, based on a thorough understanding of the product and process properties which can affect it.

The FDA started the pilot programme of drug applications relying on QbD principles in 2005, initially limiting participation to small-molecule drugs. Recent comments by Christine Moore, Acting Deputy Director of the Office of New Drug Quality Assessment at the agency's Center for Drug Evaluation and Research, indicates that for small molecules at least the concept is now moving on from the conceptual phase and is in the early stages of implementation.

The programme was extended to include complex biological molecules in 2008 because, while many of the same principles apply, the ability to assess relevant attributes is a much greater challenge for complex pharmaceuticals, according to a Federal Register notice available here.

Earlier this year the FDA updated its own guidance on ICH Q8, adding an annex that set out its interpretation of QbD principles and critical quality attributes (CQAs) defined as factors that that could be affect the strength, purity, release and stability of pharmaceutical products.

The ongoing biotechnology pilot is open to original submissions and post-approval supplements to biologics license applications (BLAs) and new drug applications (NDAs) that are reviewed by the FDA's Office of Biotechnology Products. The aim is to amass experience on QbD practices so that the agency can develop a workable guidance document for industry.

FDA Commisioner Peggy Hamburg told the Regulatory Affairs Professionals Society annual conference earlier this month: "Companies need to understand from the start what makes a quality product, rather than determining that through testing after the fact."

The ICH guidelines set out the concepts of QbD and provide a basic framework for regulation, based on knowing the risks associated with a product, and developing strategies to minimise those risks.

"Use of QbD is not mandatory," she stressed, "but many pharmaceutical companies are already seeing the benefit of incorporating the tenets of improving product quality in their product development processes."

"Hopefully approaches like QbD will lead to more efficient and rapid production of high quality medical products," Hamburg told the meeting.

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