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Design Space

 Presentation prepared by Drug Regulations – a not for
profit organization. Visit www.drugreulations.org for the
                latest in Pharmaceuticals.




                               www.drugragulations.org      1
Product Profile      Quality Target Product Profile (QTPP)


     CQA’s            Determine “potential” critical quality attributes (CQAs)


Risk Assessments      Link raw material attributes and process parameters to
                       CQAs and perform risk assessment
  Design Space        Develop a design space (optional and not required)


Control Strategy      Design and implement a control strategy

    Continual         Manage product lifecycle, including continual
  Improvement
                       improvement


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Product Profile



     CQA’s            This presentation Part IV of the
                       series “QbD for Beginners” covers
Risk Assessments
                       basic aspects of
  Design Space         ◦ Design Space
                       ◦ Design of experiments
                       ◦ Models
Control Strategy


    Continual
  Improvement




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   The relationship between the process inputs
    (material attributes and process parameters) and
    the critical quality attributes can be described as
    the design space.




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   The multidimensional combination and interaction of
    input variables (e.g., material attributes) and process
    parameters that have been demonstrated to provide
    assurance of quality.
   Working within 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 regulatory post
    approval change process.
   Design space is proposed by the applicant and is
    subject to regulatory assessment and approval (ICH
    Q8).


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   The      Multi-dimensional region   which
    encompasses the various combinations of
    product design, manufacturing process
    design, manufacturing process operating
    parameters and raw material quality which
    produce material of suitable ( defined)
    quality.




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Critical Quality Attributes

Input Materials                             Output Materials
                     Process Step           (Product or Intermediate)

Design
Space
                Input              Measured
               Process            Parameters
             Parameters           or Attributes
                                                         Process
                      Control Model
                                                         Measurements
                                                         and Controls
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100.0                                                                                              2
                   95.0
                   90.0               Surface Plot                                    Contour Plot                   1.8
Dissolution (%)




                                                                                                                     1.6
                   85.0                                                                                                                  Dissolution (%)
                   80.0                                                                                              1.4
                                                                                                                                            90.0-95.0
                    75.0




                                                                                                                           Parameter 2
                                                                                                                     1.2
                    70.0                                                                                                                    85.0-90.0

                    65.0                                                                                             1                      80.0-85.0
                    60.0                                                                                                                    75.0-80.0
                                                                                                                     0.8
                     55.0                                                                                                                   70.0-75.0
                                                                                                                     0.6
                     50.0
                                                                                       Design Space
                                                                                                                                            65.0-70.0
                                                                     2                                               0.4                    60.0-65.0
                            40
                                                                                        (non-linear)
                            Pa                                       2                                               0.2
                                 ram     50               1
                                                                er
                                    ete                       et                       Design Space
                                        r1                  am                                                       0
                                               60 0   P   ar             40 42   44   46 (linear ranges)
                                                                                            48 50 52 54    56   58 60
                                                                                         Parameter 1


                                  • Design space proposed by the applicant
                                  • Design space can be described as a mathematical function or
                                    simple parameter range
                                  • Operation within design space will result in a product meeting the
                                    defined quality attributes


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Knowledge Space

                                Design Space: “Multidimensional
          Design Space          combination and interaction of input
                                variables (e.g., material attributes) and
                                process parameters that have been
                         NOR
                                demonstrated to provide assurance of
                                quality.”



                               CQA
  Knowledge Space: “A
  summary of all process
  knowledge obtained
  during product
  development.”




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There are no
   regulatory
requirements to
 have a Design
     Space




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   Design space can illustrate understanding of
    parameter interactions and provides manufacturing
    flexibility
   Proven acceptable range alone is not a design
    space
   Design space should be verified and operational
    at full scale
   No requirement to develop a design space at the
    full manufacturing scale


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   A design space can be described in terms of ranges
    of material attributes and process parameters.
   It can also be described through more complex
    mathematical relationships.
   It is possible to describe a design space as a time
    dependent function (e.g., temperature and pressure
    cycle of a lyophilisation cycle), or
   As a combination of variables such as components
    of a multivariate model.



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Design Space




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   Scaling factors can also be included if the design
    space is intended to span multiple operational
    scales.
   Analysis of historical data can contribute to the
    establishment of a design space.
   Regardless of how a design space is developed, it
    is expected that operation within the design
    space will result in a product meeting the defined
    quality.




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   Independent design spaces can be established for one or
    more unit operations, or
   Single design space that spans multiple operations can
    also be established.
   A separate design space for each unit operation is often
    simpler to develop.
   However a design space that spans the entire process can
    provide more operational flexibility.
   For example, in the case of a drug product that undergoes
    degradation in solution before lyophilisation, the design
    space to control the extent of degradation
    (e.g., concentration, time, temperature) could be
    expressed for each unit operation or as a sum over all
    unit operations.


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Identify Q T P P


      Identify C Q A                             Risk Assessment


Define product design space


Define process design space                      Risk Assessment



Refine process design space                Process Characterization



  Define Control strategy                       Risk Assessment


    Process Validation


    Process Monitoring




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   Consider QTPP in establishing the Design Space
   Initial determination of CQAs
   Assess prior knowledge to understand variables and
    their impact
   Scientific principles & historical experience
   Perform initial risk assessment of manufacturing
    process relative to CQAs to identify the high risk
    manufacturing steps (->CPPs)
   Conduct Design of Experiments (DoE)
   Evaluate experimental data
   Conduct additional experiments/analyses as needed


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   First-principles approach
    ◦ Combination of experimental data and
      mechanistic knowledge of chemistry, physics, and
      engineering to model and predict performance
   Statistically designed experiments (DOEs)
    ◦ Efficient method for determining impact of
      multiple parameters and their interactions
   Scale-up correlation
    ◦ A semi-empirical approach to translate operating
      conditions between different scales or pieces of
      equipment



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   The risk assessment and process development
    experiments can lead to an understanding of the
    linkage and effect of process parameters and
    material attributes on product CQAs and
   Also help identify the variables and their ranges
    within which consistent quality can be achieved.
   These process parameters and material attributes
    can thus be selected for inclusion in the design
    space.




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   Prior knowledge may include :
   Internal knowledge from development and
    manufacturing
   External knowledge: scientific and technical
    publications (including literature and peer-reviewed
    publications)
   Citation in filing: regulatory filings, internal company
    report or notebook, literature reference
   No citation necessary if well known and accepted by
    scientific community


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   Risk assessment is based on prior knowledge and
    relevant experience for the product and
    manufacturing process
   Gaps in knowledge could be addressed by further
    experimentation
   Assignments of risk level must be appropriately
    justified
   Risk assessments/control will iterate as relevant new
    information becomes available
   Final iteration shows control of risks to an
    acceptable level



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◦ Design space could include critical and non-critical
 parameters
  Critical parameter ranges/model are considered a regulatory
   commitment and non-critical parameter ranges support the
   review of the filing
  Critical parameter changes within design space are handled by
   the Quality System and changes outside the design space need
   appropriate regulatory notification
◦ Non-critical parameters would be managed by Quality
 System


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   DOE useful tool in development of a DS but
    not the only one
    ◦ 1st Principles models
   DS may cover one, or multiple unit
    operation(needs to be clear in the dossier)
   Not all unit operations must have a DS
   Unit operations without a DS will obviously
    not achieve the regulatory benefits (ie, ability
    to move within DS)



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   DS is usually developed at lab scale
   There is no need to perform full DOEs at full scale to
    confirm the DS at full scale.
   Good understanding of scale up phenomena is
    needed, some parameters may be scale independent
    (needs to be justified)
   Scale up factors could be used to reduce concern about
    moving within DS at scale
   Experiments within the DS at full scale could also be used
    to reduce the same concern.
   Another option is have additional monitoring controls
    applied when there is a change within the DS to ensure
    that the DS is still valid and then relaxation to a less
    stringent control strategy.
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   DS needs to be complemented by an appropriate
    control strategy
   Critical process parameters remain critical even if
   controlled,
   CQAs: appropriate specs need to be set, even if
    not tested routinely
   Release based on CQAs and control of process
    parameters is possible if satisfactorily
    demonstrated ( e.g. dissolution release based on
    particle size control, and disintegration test)



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   One-factor-at-a-time (the classical approach)
   Designed experiments (DOE)




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   One-factor-at-a-time
    ◦ Procedure (2 level example)
      Run all factors at one condition
      Repeat, changing condition of one factor
      Continuing to hold that factor at that condition, rerun
       with another factor at its second condition
      Repeat until all factors at their optimum conditions
    ◦ Slow, expensive: many tests
    ◦ Can miss interactions!




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Process: Yield = f(temperature, pressure)

                                   50% yield

                    30% yield




               Max yield: 50% at 78 C, 130 psi?

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A better view of the maximum yield!

                    Optimized yield is over 85%




   Process: Yield = f(temperature, pressure)

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       Multiple-Factors-at-a-Time, DOE
    ◦     Full Factorials
    ◦     Fractional Factorials
    ◦     Plackett – Burman designs
    ◦     Central Composite designs




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   DOE is defined as “a structured analysis
    wherein inputs are changed and differences
    or variations in outputs are measured to
    determine the magnitude of the effect of each
    of the inputs or combination of inputs.”
   Full factorial example:
                                                        Dependent
                          Independent Variable            Variable
                          (Controlling Factors)         (Response)
                  Run    Factor X1     Factor X2        Factor Y1
                   1        High         High            Output1
                   2        Low          High            Output2
                   3        High         Low             Output3
                   4        Low          Low             Output4
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(1) Choose experimental design
    (e.g., full factorial, d-optimal)       (2) Conduct randomized
                                                 experiments
                                              Experiment    Factor A   Factor B   Factor C

                                                  1           +          -          -
      A
                                                  2           -          +          -
                                                  3           +          +          +
          B
                C                                 4           +          -          +
(3) Analyze data
                                           (4) Create multidimensional
                                                 surface model
                                               (for optimization or control)




                        www.minitab.com
                                          www.drugragulations.org
                                                                                             33
   Several families
   n = number of Factor tested and L : level/factor
   Semi Factorial Design : the lowest number of experiments required : 2n-k
   Used for a first screening of mains factors and at least single interactions
   Used for demonstration of a Proven Acceptable Range (PAR) or Design Space
    ◦   Don‟t be afraid by the number of factor.
   Factorial Design : higher number of experiments : 2n
   For both Design, only two levels (L = 2) + eventual central point(s), Models will always
    be linear.
   Response Surface Model : higher number of experiments : Ln. Non linear models.
    The number of experiments can be decreased by historical methods or by computer
    optimisation (D Optimal).
    ◦   Used for optimisation/ modeling of a process
    ◦   Used for searching the „‟ edge of failure‟‟
   Mixture : RSM + constraint (sum of component = fixed value)
           Used in chemistry, formulation,…
   Combined : Mixture + (semi) Factorial or RSM
           Used for combines mixture/process such as formulation (excipents) and freeze drying
            conditions.




                                                                                  34
   The kind of question to answer must be
    understood :
    ◦   Critical parameters
    ◦   Interactions
    ◦   Optimisation
    ◦   Demonstration of Proven Acceptable Range
    ◦   Modeling
   The experiments are planned before starting
   Apparently a high number of experiments, more
    work, more time, more money.
   In reality, far less experiments (semi factorial or
    reduction for RSM) to obtain far less valuables
    results. Allow a better planning of experiments
    including Analytical.

                                                   35
   Randomization, blocking and replication are the three
    basic principles of statistical experimental design.
   By properly randomizing the experiment, the effects of
    uncontrollable factors that may be present can be
    “averaged out”.
   Blocking is the arrangement of experimental units into
    groups (blocks) that are similar to one another.
   Blocking reduces known but irrelevant sources of variation
    between groups and thus allows greater precision in the
    estimation of the source of variation under study.
   Replication allows the estimation of the pure experimental
    error for determining whether observed differences in the
    data are really statistically different


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   ANOVA results should accompany all DOE data
    analysis, especially if conclusions concerning the significance of
    the model terms are discussed.
   For all DOE data analysis, the commonly used alpha of 0.05 is
    chosen to differentiate between significant and non significant
    factors.
   It is important that any experimental design has sufficient power
    to ensure that the conclusions drawn are meaningful.
   Power can be estimated by calculating the signal to noise ratio.
   If the power is lower than the desired level, some remedies can
    be employed to increase the power.
   For example, by adding more runs, increasing the signal or
    decreasing the system noise.
   ICH Points to Consider document for guidance on the level of
    DOE documentation recommended for regulatory submissions.


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   A design space can be updated over the lifecycle as
    additional knowledge is gained.
   Risk assessments, as part of the risk management process,
    help steer the focus of development studies and define the
    design space.
   Operating within the design space is part of the control
    strategy.
   The design space associated with the control strategy
    ensures that the manufacturing process produces a product
    that meets
    ◦ The Quality Target Product Profile (QTPP) and
    ◦ Critical Quality Attributes (CQAs).




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   Since design spaces are typically developed at small
    scale, an effective control strategy helps manage
    potential residual risk after development and
    implementation.
   When developing a design space for a single-unit
    operation, the context of the overall manufacturing
    process can be considered, particularly immediate
    upstream and downstream steps that could interact
    with that unit operation.
   Potential linkages to CQAs should be evaluated in
    design space development.


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   In developing design spaces for existing
    products, multivariate models can be used for
    retrospective evaluation of historical production
    data.
   The level of variability present in the historical
    data will influence the ability to develop a design
    space, and additional studies might be
    appropriate.




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   Design spaces can be based on
    ◦ scientific first principles and/or
    ◦ empirical models.
   An appropriate statistical design of experiments
    incorporates a level of confidence that applies to
    the entire design space, including the edges of an
    approved design space.




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   However, when operating the process near the
    edges of the design space, the risk of excursions
    from the design space could be higher because of
    normal process variation (common cause
    variation).




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   The control strategy helps manage residual risk
    associated with the chosen point of operation
    within the design space.
   When changes are made
    (e.g., process, equipment, raw material
    suppliers), results of risk review can provide
    information regarding additional studies and/or
    testing that might verify the continued
    applicability of the design space and associated
    manufacturing steps after the change.


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   Capturing development knowledge and
    understanding contributes to design space
    implementation and continual improvement.
   Different approaches can be considered when
    implementing a design space (e.g., process
    ranges, mathematical expressions, or feedback
    controls to adjust parameters during processing
    (see also Figure 1d in ICH Q8(R2)).
   The chosen approach would be reflected in the
    control strategy to assure the inputs and process
    stay within the design space.


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   Although the entire design space does not have
    to be reestablished (e.g., DoE) at commercial
    scale, design spaces should be initially verified as
    suitable prior to commercial manufacturing.
   Design space verification should not be confused
    with process validation.
   However, it might be possible to conduct
    verification studies of the performance of the
    design space scale-dependent parameters as part
    of process validation.


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   Design space verification includes monitoring or
    testing of CQAs that are influenced by scale-
    dependent parameters.
   Additional verification of a design space might be
    triggered by changes (e.g., site, scale, or
    equipment).
   Additional verification is typically guided by the
    results of risk assessments of the potential
    impacts of the change(s) on design space.




                               www.drugragulations.org   46
   A risk-based approach can be applied to
    determine the design of any appropriate studies
    for assessment of the suitability of a design space
    across different scales.
   Prior knowledge and first principles, including
    simulation models and equipment scale-up
    factors, can be used to predict scale-independent
    parameters.
   Experimental studies could help verify these
    predictions.


                              www.drugragulations.org     47
   Some aspects of the design space that could be
    considered for inclusion in the regulatory submission:
   The design space description, including critical and
    other relevant parameters.
   The design space can be presented as ranges of
    material inputs and process parameters, graphical
    representations, or through more complex
    mathematical relationships.
   The relationship between the inputs (e.g., material
    attributes and/or process parameters) and the CQAs,
    including an understanding of the interactions among
    the variables.




                                www.drugragulations.org      48
   Data supporting the design space, such as prior
    knowledge, conclusions from risk assessments as part
    of QRM, and experimental studies with supporting
    data, design assumptions, data analysis, and models.
   The relationship between the proposed design space
    and other unit operations or process steps.
   Results and conclusions of the studies, if any, of a
    design space across different scales.
   Justification that the control strategy ensures that the
    manufacturing process is maintained within the
    boundaries defined by the design space.



                                 www.drugragulations.org       49
   The control strategy used for implementation
    of a design space in production depends on
    the capabilities of the manufacturing site.
   The batch records reflect the control strategy
    used.
   For example, if a mathematical expression is
    used for determining a process parameter or
    a CQA, the batch record would include the
    input values for variables and the calculated
    result.


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   As part of the technology transfer of a design space
    to a site and throughout the lifecycle, it is important
    to share the knowledge gained during development
    and implementation that is relevant for using that
    design space both on the manufacturing floor and
    under the PQS of the company or site.
   This knowledge can include results of risk
    assessments, assumptions based on prior knowledge,
    and statistical design considerations.
   Linkages among the design space, control strategy,
    CQA, and QTPP are an important part of this shared
    knowledge.


                                 www.drugragulations.org      51
   Each company can decide on the approach
    used to capture design space information and
    movements within the design space under the
    applicable PQS, including additional data
    gained through manufacturing experience
    with the design space.
   In the case of changes to an approved design
    space, appropriate filings should be made to
    meet regional regulatory requirements.


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   Movement within the approved design
    space, as defined in the ICH Q8(R2)
    glossary, does not call for a regulatory filing.
   For movement outside the design space, the
    use of risk assessment could be helpful in
    determining the impact of the change on
    quality, safety, and efficacy and the
    appropriate regulatory filing strategy, in
    accordance with regional requirements.


                              www.drugragulations.org   53
   A model is a simplified representation of a
    system using mathematical terms.
   Models can enhance scientific understanding
    and
   Possibly predict the behavior of a system
    under a set of conditions.
   Mathematical models can be used at every
    stage of development and manufacturing.



                             www.drugragulations.org   54
   They can be derived from
    ◦ first principles reflecting physical laws (such as
      mass balance, energy balance, and heat transfer
      relations), or
    ◦ From data, or
    ◦ From a combination of the two.




                                  www.drugragulations.org   55
   There are many types of models.
   The selected one will depend on
    ◦ The existing knowledge about the system,
    ◦ The data available, and
    ◦ The objective of the study.




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   Models can be categorized in multiple ways.
   The categorization approaches are intended
    to facilitate the use of models across the
    lifecycle, including
    ◦ Development,
    ◦ Manufacturing,
    ◦ Control, and
    ◦ Regulatory processes.




                              www.drugragulations.org   57
   For the purposes of regulatory submissions,
    an important factor to consider is the model‟s
    contribution in assuring the quality of the
    product.
   The level of oversight should be
    commensurate with the level of risk
    associated with the use of the specific
    model.




                             www.drugragulations.org   58
   Low-Impact Models:
    These models are typically used to support
    ◦ Product and/or
    ◦ Process development
    ◦ (e.g., formulation optimization).




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   Medium-Impact Models:
    Such models can be useful in assuring quality
    of the product.
   However these models are not the sole
    indicators of product quality
   (e.g., most design space models, many in-
    process controls).




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   High-Impact Models:
    A model can be considered high impact if
    prediction from the model is a significant
    indicator of quality of the product.
   (e.g., a chemometric model for product assay,
    a surrogate model for dissolution).




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   For the purpose of implementation, models
    can also be categorized on the basis of the
    intended outcome of the model.
   Within each of these categories, models can
    be further classified as
    ◦ Low,
    ◦ Medium or
    ◦ High,
   Classification based on their impact in
    assuring product quality.

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   Models for supporting process design:
    This category of models includes (but is not
    limited to) models for
    ◦ Formulation optimization,
    ◦ Process optimization
      (e.g., reaction kinetics model),
    ◦ Design space determination, and
    ◦ Scale-up.




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   Models for supporting process design:
   Models within this category can have different
    levels of impact.
   For example, a model for design space
    determination would generally be considered
    a medium-impact model,
   While a model for formulation optimization
    would be considered a low-impact model.


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   Models for supporting analytical procedures:
    In general, this category includes empirical
    (i.e., chemometric) models based on data
    generated by various Process Analytical
    Technology (PAT)-based methods.




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   Models for supporting analytical procedures:
   A calibration model associated with a near
    infrared (NIR)-based method.
   Models for supporting analytical procedures
    can have various impacts depending on the
    use of the analytical method.
   For example, if the method is used for release
    testing, then the model should be high-
    impact.

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   Models for process monitoring and control:
    ◦ Univariate Statistical Process Control (SPC) or
    ◦ Multivariate Statistical Process Control (MSPC)-
     based models:
   These models are used to detect special
    cause variability;
   The model is usually derived and the limits
    are determined using batches manufactured
    within the target conditions.



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   Models for process monitoring and control:
   If an MSPC model is used for continuous
    process verification along with a traditional
    method for release testing, then the MSPC
    model would likely be classified as a
    medium-impact model.




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   Models for process monitoring and control:
   However, if an MSPC model is used to support
    a surrogate for a traditional release testing
    method in an RTRT approach, then the model
    would likely be classified as a high-impact
    model.




                            www.drugragulations.org   69
   Models used for process control (e.g., feed
    forward or feedback).
   Data-driven models should be developed
    through appropriately designed experiments.
   These models are typically medium-impact or
    high-impact.
   For example, a feed forward model to adjust
    compression parameters on the basis of
    incoming material attributes could be
    classified as a medium-impact model.

                             www.drugragulations.org   70
   Sequential steps
   Steps can be repeated to impart an iterative
    nature to this process.
   Overall steps are given in following slides:




                           www.drugragulations.org   71
1.       Defining the purpose of the model.
2.       Deciding on the type of modeling approach.
     ◦    (e.g. mechanistic or empirical) and
     ◦    Possible experimental/sampling methodology to
          be used to support the model development.




                                   www.drugragulations.org   72
3.       Selecting variables for the model; this is
         typically based on
     ◦    Risk assessment,
     ◦    Underlying physicochemical phenomena,
     ◦    Inherent process knowledge, and
     ◦    Prior experience.




                                 www.drugragulations.org   73
4.       Understanding the limitations of the model
         assumptions to:
     ◦     Correctly design any appropriate experiments;
     ◦     Interpret the model results; and
     ◦     Include appropriate risk-reduction strategies.




                                   www.drugragulations.org   74
5.       Collecting experimental data to support
         model development.
     ◦       These data can be collected at
             Laboratory,
             Pilot, or
             Commercial scale,   (depending on the nature of the model. )

     ◦       It is important to ensure that variable ranges
             evaluated during model development are
             representative of conditions that would be
             expected during operation.


                                              www.drugragulations.org        75
6.   Developing model equations estimating
     parameters, based on a scientific
     understanding of the process and collected
     experimental data.




                           www.drugragulations.org   76
7.       Validating the model, as appropriate.
8.       In certain cases, evaluating the impact of
         uncertainty in model prediction on product
         quality.
     ◦       If appropriate, defining an approach to reduce
             associated residual risk
             (e.g., by incorporating appropriate control strategies
              (this can apply to high-impact and medium-impact
              models)).



                                        www.drugragulations.org        77
9.       Documenting the outcome of model.
     ◦    Development
     ◦    Assumptions
        Developing plans for verification and update
         of the model throughout the lifecycle of the
         product.
        The level of documentation would be
         dependent on the impact of the model


                                www.drugragulations.org   78
   Model validation is an essential part of model
    development and implementation.
   Once a model is developed and
    implemented, verification continues
    throughout the lifecycle of the product.




                             www.drugragulations.org   79
   In the case of well-established first principles-
    driven models, prior knowledge can be leveraged
    to support model validation and verification, if
    applicable.
   The following elements can be considered for
    model validation and verification and generally
    are appropriate for high-impact models
   The applicability of the elements listed below for
    medium-impact or low-impact models can be
    considered on a case-by-case basis.



                               www.drugragulations.org   80
   Acceptance criteria relevant to the purpose and
    to its expected performance.
   In setting the acceptance criteria, variability in
    sampling procedure (e.g., for blending) could
    also be considered.
   In situations where the model is to be used to
    support a surrogate for a traditional release
    testing method, the accuracy of the model
    performance versus the reference method could
    be considered.



                                www.drugragulations.org   81
   For example, a multivariate model (e.g. a
    partial least squares (PLS) model), when
    appropriate, can be used as a surrogate for
    traditional dissolution testing.
   In this case, the PLS model should be
    developed in terms of in-process parameters
    and material attributes and can be used to
    predict dissolution.




                            www.drugragulations.org   82
   One of the ways to validate and verify model
    performance in this case would be to
    compare accuracy of prediction of the PLS
    model with the reference method (e.g., a
    traditional dissolution method).




                            www.drugragulations.org   83
   Comparison of the accuracy of calibration
    versus the accuracy of prediction.
   This can often be approached through
    internal cross-validation techniques using the
    same data as the calibration data set.




                             www.drugragulations.org   84
   It can be beneficial to verify the prediction accuracy of the
    model by parallel testing with the reference method during
    the initial stage of model implementation.
   This testing can be repeated throughout the lifecycle, as
    appropriate.
   If models are used to support a design space at
    commercial scale or are part of the control strategy, it is
    important to verify the model at commercial scale.
    ◦ If a calibration model associated with an NIR-based method is
      developed at the laboratory scale and the method is then
      transferred to and used in commercial scale.




                                        www.drugragulations.org       85
   In addition, the data sets used for calibration,
    internal validation, and external validation
    should take into account the variability
    anticipated in future routine production
    ◦ (e.g., a change in the source of raw material that
      might impact NIR prediction).
   Low-impact models typically do not call for
    verification.




                                  www.drugragulations.org   86
   Approaches for model verification can be
    documented according to the PQS of the
    company and can include the following:
    ◦ A risk-based frequency of comparing the model‟s
      prediction with that of the reference method,
    ◦ Triggers for model updates (e.g., because of changes in
      raw materials or equipment),
    ◦ Procedures for handling model-predicted Out of
      Specification (OOS) results,
    ◦ Periodic evaluations, and approaches to model
      recalibration




                                   www.drugragulations.org      87
   The level of detail for describing a model in a
    regulatory submission is dependent on the
    impact of its implementation in assuring the
    quality of the product.
   For the various types of models, the applicant
    can consider including:




                             www.drugragulations.org   88
   Low-Impact Models:
    A discussion of how the models were used to
    make decisions during process development.




                           www.drugragulations.org   89
   Medium-Impact Models:
    ◦ Model assumptions,
    ◦ A tabular or graphical summary of model inputs and
      outputs,
    ◦ Relevant model equations (e.g., for mechanistic models),
    ◦ Statistical analysis where appropriate,
    ◦ a comparison of model prediction with measured data,
      and
    ◦ A discussion of how the other elements in the control
      strategy help to mitigate uncertainty in the model, if
      appropriate.




                                   www.drugragulations.org       90
   High-Impact Models:
    Data and/or prior knowledge (e.g., for established first
    principles-driven models) such as
    ◦ Model assumptions,
    ◦ Appropriateness of the sample size, number and distribution of
      samples,
    ◦ Data pretreatment,
    ◦ Justification for variable selection,
    ◦ Model inputs and outputs,
    ◦ Model equations,
    ◦ Statistical analysis of data showing fit and prediction ability,
    ◦ Rationale for setting of model acceptance criteria,
    ◦ Model validation (internal and external), and
    ◦ A general discussion of approaches for model verification during
      the lifecycle.



                                        www.drugragulations.org          91
Rittinger’s law: The work required in crushing is
proportional to the new surface created.



Where: P=power required, dm/dt=feed rate to crusher, Dsb =
ave diameter before crushing, DSQ=ave after crushing,
Kr=Rittinger’s coef.

Kick’s law: the work required for crushing a given mass of
material is constant for the same reduction ratio, that is the
ratio of the initial particle size to the finial particle size



Kk=Kick’s coef.
For fine grains, the                                   Characteristic region
boundary between
the characteristic
                              Blender head space
region and the
remaining powder
bed is parabolic in
shape



                                                   n
                         m           o                     m
The powder bed         Vr      rV                      V  r 1
below the boundary
                                               r 1
rotates with the
mixer as a solid       as fraction mixed
body.
                                                   n
                       f rm     rf   o
                                                        f rm1
                                              r 1
0.40
                                      Avicel® PH-200 compacts

                                       VFS Speed: 200 rpm
                        0.35           HFS Speed: 30 rpm
                                     Roll Pressure: 6560 lb/in
Slope of NIR Spectrum




                        0.30


                                                                                                                Roll Speed (RPM)
                        0.25
                                                                 y = 0.3672x + 0.1754
                                                                                                                  4          5        6
                                                                      R2 = 0.9899
                                                                                                                  7          8        9
                        0.20
                                                                                                                  10         11       12



                        0.15
                               0.0    0.1              0.2           0.3                              0.4              0.5                 0.6
                                                                                                      20
                                                  Force at break/Thickness/Width (N/mm2)
                                                                                                      18                                                 Avicel® PH-200 compacts


                         The strength is a                                                           16
                                                                                                                                                        VFS Speed: 194 - 197 rpm
                                                                                                                                                        HFS Speed: 29 - 30 rpm
                                                                                                                                                           Roll Gap: 0.031 - 0.038"

                          linear function of the                                                      14                                              Roll Pressure:   6551 lb/in
                                                                                 Force at break (N)



                                                                                                      12
                          density which is                                                            10

                          monitored by NIR                                                             8
                                                                                                                                                                 y = 21.54e
                                                                                                                                                                            -0.4493x



                         Semi Empirically
                                                                                                       6
                                                                                                                                                                   R2 = 0.9884
                                                                                                       4


                        F=(SNIR-0.17)/0.37                                                             2

                                                                                                       0
                                                                                                            4          5          6          7          8         9        10          11   12
                                                                                                                                                 Roll Speed (RPM)
Avicel® PH-200 Milled Compacts

                     1000                                      Increaing Roll Speed
                                                                                                                  Day1

                                                                                                                  Day2
                      800
Particle Size ( m)




                                                                                                                        d90
                      600




                      400
                                                                                                                        d50


                      200                                                                                               d10




                         0
                             3   4   5    6       7          8         9                           10     11     12          13
                                                      Roll Speed (rpm)                                                      Avicel® PH-200 Milled Compacts
                                                                                            1200
                                                                                                                                 Increaing Roll Speed

                            The particle sizes                                                          d90                                                               Day1



                             of the milled
                                                                                            1000
                                                                                                                                                                           Day2




                             material is also                                                800
                                                                       Particle Size ( m)




                             manifest in the                                                 600
                                                                                                         d50


                             slope of the NIR
                             signal (as
                                                                                             400
                                                                                                         d10



                             predicted)                                                      200



                                                                                               0
                                                                                                   2.0     2.5        3.0         3.5          4.0       4.5   5.0   5.5          6.0
                                                                                                                                    1 / Slope NIR Spectrum
Optimum
                                                                                         Conditions

                               (u,v)=       *(u,v)
                                        0
Equilibrium Moisture Content




                                                                                                      SIZE
                                               M=M0-Kt


                                                                                    M=M0’exp(-K’t)
                                                                                    18                                                                     0.600

                                             GRANULATION TIME
                                                                                    16
                                                                                                                                                           0.550
                                                                                    14
                                                         Moisture Content (% w/w)




                                                                                                                                                                   Mean Particle Size (mm)
                                                                                    12                                                                     0.500
                                                                                                                                  Moisture Content
                                                                                                                                  Particle Size
                                                                                    10
                                                                                                                                                           0.450
                                                                                    8


                                                                                    6                                                                      0.400

                                                                                    4
                                                                                                                                                           0.350
                                                                                    2


                                                                                    0                                                                      0.300
                                                                                         0              20   40            60      80                100
                                                                                                             Elapsed Time (min)
Funicular   Modeling
                                 Wet
                                 Granulation
Pendular

           Over
           Wetting


Droplet
                     Capillary
           Drying
0.0010                                    X1=110 g
                                        H13 (1 min)     (=X3)
                                        H15 (3.5 min)            X2=255 rpm
NIR Treated Response




                                        H14 (6 min)
                       0.0008
                                                                            610 m
                                                                 410 m
       Slope




                                                  320 m
                       0.0006




                       0.0004



                                    MIXING    SPRAYING          WET MASSING
                       0.0002
                                0       100      200       300      400       500   600

                                                    Process time (s)
[Kunii and Levenspiel, Fluidization Engineeri
                                           [Kunii and Levenspiel, Fluidization Engineering, Pub. Krieger, pg. 424-428,1977]

                  180                                                                                                                           65


                            Evaporative




                                              Moisture Content




                                                                                                           Temperature
                                                                                                                                                63
                  160
                            Q Qo Kt
                                                                                                                                                61

                                                                      Critical
                  140                                                 moisture




                                                                                                                                                     Temperature (°C)
                                                                                                                                                59
   MM55 Reading




                                                                                                                              T                 57
                  120

                                                                                                                                                55

                  100
                                                                                                                                                53



                  80                                                                                      Diffusive                             51


                                      MM55                                                     Q Q                       Q'ok EXP( k' t)        49

                  60
                                                                                                                                                47



                  40                                                                                                                            45
                        0         5                              10                    15            20                       25           30

                                                                                 Drying Time (min)

K.R. Morris, S.L. Nail, G.E. Peck, S.R. Byrn, U.J. Griesser, J.G. Stowell, S.-J. Hwang, K. Park Pharm Sci Tech Today 1 6 235–245 (1998).
235
NIR Monitor (Arbitrary Values)



                                 215

                                 195

                                 175

                                 155

                                 135

                                 115                                                 Conventional Drying

                                           Fast Drying
                                  95

                                  75
                                    0.00    5.00         10.00         15.00         20.00          25.00
                                                                 Time (min)

                                                                  Morris et.al., Drug Dev. Ind. Pharm., 26 (9):985-
60.00
                     240.0
                                                                                                            Average Exhaust Temp
                                                                                                                                                            55.00
                     220.0
MM55 Gauge Reading



                     200.0                                                                                                                                  50.00

                     180.0                                                                                                                                  45.00

                     160.0
                                                                                                                                                            40.00
                     140.0
                                                                                                Active Melting Temp                                         35.00
                     120.0
                                                                                                                                                            30.00
                     100.0

                      80.0                                                                                                                                  25.00

                      60.0                                                                                                                                  20.00
                             0.0          5.0          10.0         15.0        20.0             25.0                        30.0          35.0         40.0
                                                                   Elapsed Drying Time (min)
                                                                                                                       120
                         Batch 018 sub1     Batch 018 sub2    Batch 019 sub1   Batch 019 sub2      Batch 020 sub1                   Batch 021 sub1   Batch 021 sub2

                                                                                                   Average % Release   100

                                                                                                                        80

                                                                                                                        60

                                                                                                                        40
                                                                                                                                                                                    Baseline Data
                                                                                                                        20
                                                                                                                                                                                    Temp Excursion
                                                                                                                         0
                                                                                                                             0              20            40            60         80    100        120
                                                                                                                                                                      Time (min)
WHOLE TABS                HALF TABS               QUARTER TABS
         Active 1   Active 2       Active 1   Active 2      Active 1   Active 2
MEAN      101.9      100.9          101.8      99.6          102.1       100.5
SD         0.7        1.6            1.4        2.8           2.4         5.1
CV (%)     0.7        1.6            1.3        2.8           2.3         5.1

 CU for constant size portions of tablets must be larger than for the
 whole, so in spec using real time monitoring of “part” of the tablets
 means in spec for the whole tablet
                             CVP        CVT
                                        T. Li, et. al., in press Pharm. Res.
                                     BioMed Anal.
HPMC and Sulfanilamide Calculations (Peak Height)
                         0.4



                        0.35
Absorbance (log(1/R))




                         0.3
                                                                                                   HPMC
                                                                                                   Sulfanilamide
                        0.25



                         0.2



                        0.15
                               0        30           60                                  90               120           150
                                                      Elapsed Time (min)

                                                                                        200                                                                                700



                                                                                        100
                                                                                                                                                                           500
                                                                  Sulfanilamide Gauge




                                                                                          0




                                                                                                                                                                                  M oisture Gauge
                                                                                                                                        Sulfanilam ide                     300
                                                                                                                                        Moisture
                                                                                        -100

                                                                                                                                                                           100
                                                                                        -200


                                                                                                                                                                           -100
                                                                                        -300



                                                                                        -400                                                                               -300
                                                                                               0     20            40   60         80        100         120   140   160
                                                                                                                              Elapsed Time (min)
   These principles and techniques are applicable to
    batch and continuous processing and may be
    linked by multi-variate (chemometric) methods
    after univariate conformation.
   Ultimately this give us the ability to understand
    how development variables interact to influence the
    final product and to design in the quality




                                                          10
                               www.drugragulations.org     4
Quality by Design for ANDAs:
An Example for Immediate-Release
          Dosage Forms
            Published by FDA




                        www.drugragulations.org   105
Aqueous           0.1 N HCL             0.015 mg/ml
solubility as a
                  pH 4.5 buffer         0.015 mg/ml
function of
pH:
                  pH 6.8 buffer         0.015 mg/ml
Hyroscopicity     Acetriptan Form III is non-hygroscopic and requires no special protection
                  from humidity during handling, shipping or storage
Density (Bulk,    •   Bulk density: 0.27 g/cc
Tapped, and       •   Tapped density: 0.39 g/cc
True) and         •   True density: 0.55 g/cc
Flowability:      •   The flow function coefficient (ffc) was 2.95 and the Hausner ratio was
                      1.44 which both indicate poor flow properties.
Chemical          •   pKa: Acetriptan is a weak base with a pKa of 9.2.
properties        •   Overall, acetriptan is susceptible to dry heat, UV light and oxidative
                      degradation.

Biological        •   Partition coefficient: Log P 3.55 (25 °C, pH 6.8)
properties        •   Caco-2 permeability: 34 × 10-6 cm/s. Therefore, acetriptan is highly
                      permeable.
                  •   BCS Class II compound (low solubility and high permeability)


                                                       www.drugragulations.org                 106
Drug Substance Attributes
Drug          Solid   PSD    Hygrosc   Solubil   Mois   Residual      Process   Chemi     Flow
Product       State          opicity   ity       ture   Solvent       Impurit   cal       prop
                                                 Cont
CQA           Form                                                    ies       stabili
                                                 ent
                                                                                ty
Assay         Low     Med     Low       Low      Low       Low          Low      High     Med
CU            Low     High    Low       Low      Low       Low          Low      Low      High
Dissolution   High    High    Low       High     Low       Low          Low      Low      Low

Degradation   Med     Low     Low       Low      Low       Low          Low      High     Low
products




                                                  www.drugragulations.org                        107
Component            Function                Unit           Unit
                                                    ( mg/tablet)    ( % W/W)
Acetriptan, USP              Active                         20        10
Lactose Monohydrate, NF      Filler                      64-86       32-43
Microcrystalline Cellulose   Filler                      72-92       36-46
(MCC), NF
Croscarmellose Sodium        Disintegrant                 2-10        1-5
(CCS), NF
Magnesium Stearate, NF*      Lubricant                     2-6        1-3
Talc, NF                     Glidant/Lubricant            1-10       0.5-5
Total tablet weight                                        200        100



                                          www.drugragulations.org              108
Formulation Variables
Drug product   DS PSD    MCC/      CCS Level         Talc Level   Mag Stearate
CQA                     Lactose                                      Level
                         ratios
Assay          Medium   Medium        Low                Low          Low
Content         High     High         Low                Low          Low
Uniformity
Dissolution     High    Medium       High                Low         High

Degradation     Low      Low          Low                Low        Medium
Products




                                     www.drugragulations.org                     109
   Formulation development focused on evaluation of
    the high risk formulation variables as identified in the
    initial risk assessment shown earlier.
   The development was conducted in two stages.
   The first formulation study evaluated the impact of
    the drug substance particle size distribution, the
    MCC/Lactose ratio and the disintegrant level on the
    drug product CQAs.
   The second formulation study was conducted to
    understand the impact of extragranular magnesium
    stearate and talc level in the formulation on product
    quality and manufacturability.
   Formulation development studies were conducted at
    laboratory scale (1.0 kg, 5,000 units).
                                  www.drugragulations.org      110
   Goal of Formulation Development Study #1
   Select the MCC/Lactose ratio and
   Disintegrant level and
   To understand if there was any interaction of
    these variables with drug substance particle size
    distribution.
   This study also sought to establish the
    robustness of the proposed formulation.
   A 2³ full factorial Design of Experiments (DOE)
    with three center points was used to study the
    impact of these three formulation factors on the
    response variables.

                               www.drugragulations.org   111
Process step                                 Equipment
Pre-Roller Compaction      4 qt V-blender
Blending and Lubrication   o 250 revolutions for blending (10 min at 25 rpm)
                           Alexanderwerk10 WP120 with 25 mm roller width and 120
                           mm roller diameter
                           o Roller surface: Knurled
Roller Compaction and      o Roller pressure: 50 bar
Integrated Milling         o Roller gap: 2 mm
                           o Roller speed: 8 rpm
                           o Mill speed: 60 rpm
                           o Coarse screen orifice size: 2.0 mm
                           o Mill screen orifice size: 1.0 mm
Final Blending and         4 qt V-blender
Lubrication                o 100 revolutions for granule and talc blending (4 min at 25
                           rpm)
                           o 75 revolutions for lubrication (3 min at 25 rpm)
                           16-station rotary press (2 stations used)
                           o 8 mm standard round concave tools
Tablet Compression         o Press speed: 20 rpm
                           o Compression force: 5-15 kN
                           o Pre-compression force: 1 kN

                                               www.drugragulations.org                    112
Factors : Formulation Variables                          Levels
                                               -1                0    +1
A   Drug substance PSD (d90, μm)               10                20   30

B   Disintegrant (%)                            1                3     5

C   % MCC in MCC/Lactose combination          33.3               50   66.7




                                       www.drugragulations.org               113
Responses                                  Goal                Acceptable
                                                                                            Range
Y1    Dissolution at 30 min (%) (with hardness of 12.0 kP)     Maximize                ≥ 80%


Y2    Disintegration time (min) (with hardness of 12.0 kP)     Minimize                < 5 min

Y3    Tablet content uniformity (% RSD)                        Minimize % RSD          < 5%

Y4    Assay (% w/w)                                            Target at 100 %         95.0 to 105.0 w/w
Y5    Powder blend flow function coefficient ( ffc)            Maximize                >6

Y6    Tablet Hardness @ 5 kN ( kP )                            Maximize                > 5 kP

Y7    Tablet Hardness @ 10 kN ( kP )                           Maximize                > 9 kP

Y8    Tablet Hardness @ 15 kN ( kp )                           Maximize                > 12 kP

Y9    Friability@ 5 kN ( kp )                                  Maximize                <1%

Y10   Friability@ 10 kN ( kp )                                 Maximize                <1%

Y11   friability@ 15 kN ( kp )                                 Maximize                <1%

Y12   Degradation products (%) (observed at 3 months, 40       Minimize                ACE12345: NMT 0.5%
      °C/75% RH)                                                                       Any unknown impurity:
                                                                                       NMT 0.2%
                                                                                       Total impurities: NMT
                                                                                       1.0%

                                                             www.drugragulations.org                           114
A             B           C          Y1              Y3         Y5        Y7
    Batch    DS PSD     Disintegra    % MCC     Dissolution      Content       Ffc     Tablet
     No                  nt level    in MCC/        in          Uniformity    Value   Hardness
                                      Lactose     30 min                              @ 10 kN
                                        Mix
            (d90, μm)      ( %)        (%)         (%)           ( % RSD )    --        (kP)

1              30           1         66.7         76.0             3.8       7.56     12.5

2              30           5         66.7         84.0             4.0       7.25     13.2

3              20           3         50.0         91.0             4.0       6.62     10.6

4              20           3         50.0         89.4             3.9       6.66     10.9

5              30           1         33.3         77.0             2.9       8.46      8.3

6              10           5         66.7         99.0             5.1       4.77     12.9

7              10           1         66.7         99.0             5.0       4.97     13.5

8              20           3         50.0         92.0             4.1       6.46     11.3

9              30           5         33.3         86.0             3.2       8.46      8.6

10             10           1         33.3         99.5             4.1       6.16      9.1

11             10           5         33.3         98.7             4.0       6.09      9.1


                                                    www.drugragulations.org                      115
   Initially, dissolution was tested using the FDA-
    recommended method.
   All batches exhibited rapid and comparable
    dissolution (> 90% dissolved in 30 min) to the RLD.
   All batches were then retested using the in-house
    dissolution method .
   Results are presented in earlier table.
   Since center points were included in the DOE, the
    significance of the curvature effect was tested
    using an adjusted model.
   The Analysis of Variance (ANOVA) results are
    presented in next table


                               www.drugragulations.org    116
Source                            Sum of    df      Mean         F value    P value   Comme
                                  squares          square                               nts
Model                             742.19    3      247.40        242.94    < 0.0001   Significant


A- Drug Substance PSD (d90, μm)   699.8     1      699.78        657.72    < 0.0001   Significant


B- Disintegrant ( % )             32.81     1      32.81         32.21      0.0013    Significant


AB – Interaction                  39.61     1      39.61         38.89      0.0008    Significant


Curvature                          1.77     1       1.77          1.74      0.2358       Not
                                                                                      Significant

Residual                           6.11     6       1.02           ---      -----        ----


Lack of fit                        2.67     4       0.67          0.39     0.8090        Not
                                                                                      Significant

Pure error                         3.44     2       1.72          ----       ----      ------


Total                             750.07    10       ---          ----      -----       -----




                                                 www.drugragulations.org                            117
   The curvature effect was not significant for
    dissolution;
   Therefore, the factorial model coefficients were
    fit using all of the data (including center points).
   As shown in ANOVA results of the unadjusted
    model (next slide), the significant factors
    affecting tablet dissolution were
   A (drug substance PSD),
   B (disintegrant level) and
   AB (an interaction between drug substance PSD
    and the intragranular disintegrant level).


                                 www.drugragulations.org   118
Source                            Sum of    df      Mean         F value    P value   Comme
                                  squares          square                               nts
Model                             742.19    3      247.40        219.84    < 0.0001   Significant


A- Drug Substance PSD (d90, μm)   699.8     1      699.78        595.19    < 0.0001   Significant


B- Disintegrant ( % )             32.81     1      32.81         29.15      0.0010    Significant


AB – Interaction                  39.61     1      39.61         35.19      0.0006    Significant


Residual                           7.88     7       1.13           ---      -----        ----


Lack of fit                        4.44     5       0.89          0.52     0.7618        Not
                                                                                      Significant

Pure error                         3.44     2       1.72          ----       ----      ------


Total                             750.07    10       ---          ----      -----       -----




                                                 www.drugragulations.org                            119
Under Quality by Design, establishing a design
space or using real-time release testing is not
     necessarily expected (ICH Q8(R2)).




                                                    12
                          www.drugragulations.org    0
   It is not necessary to study multivariate
    interactions of all parameters to develop a
    design space.
   The applicant should justify the choice of
    material attributes and parameters for
    multivariate experimentation based on risk
    assessment and desired operational
    flexibility.


                                                      12
                            www.drugragulations.org    1
   When appropriately justified design space can be
    applicable to scale-up.
   Design space can be applicable to a site change.
   It is possible to justify a site change using a site
    independent design space based on a
    demonstrated understanding of the robustness
    of the process and an in depth consideration of
    site specific factors (e.g., equipment, personnel,
    utilities, manufacturing environment, and
    equipment).

                                                           12
                                www.drugragulations.org     2
   There are region specific regulatory
    requirements associated with site changes
    that need to be followed.
   Design space can be developed for a single
    unit operations or across a series of unit
    operations.




                                                      12
                            www.drugragulations.org    3
   It is possible to develop a design space for
    existing products.
   Manufacturing data and process knowledge
    can be used to support a design space for
    existing products.
   Relevant information should be utilized from
    ◦   Commercial scale manufacturing,
    ◦   Process improvement,
    ◦   Corrective and preventive action (CAPA), and
    ◦   Development data


                                                             12
                                   www.drugragulations.org    4
   For manufacturing operations run under narrow
    operational ranges in fixed equipment, an expanded
    region of operation and an understanding of multi
    parameter interactions may not be achievable from
    existing manufacturing data alone.
   Additional studies may provide the information to
    develop a design space.
   Sufficient knowledge should be demonstrated, and
    the design space should be supported experimentally
    to investigate interactions and establish
    parameter/attribute ranges.

                                                          12
                               www.drugragulations.org     5
   There is no regulatory expectation to develop a
    design space for an existing product.
   Development of design space for existing
    products is not necessary unless the applicant
    has a specific need and
   Desires to use a design space as a means to
    achieve a higher degree of product and process
    understanding.
   This may increase manufacturing flexibility
    and/or robustness.

                                                        12
                              www.drugragulations.org    6
   Design space can be applicable to formulations.
   It may be possible to develop formulation (not
    component but rather composition) design space
    consisting of the
    ◦ ranges of excipient amount and
    ◦ its physicochemical properties (e.g., particle size
      distribution, substitution degree of polymer)
   Based on an enhanced knowledge over a wider
    range of material attributes.


                                                               12
                                     www.drugragulations.org    7
   The applicant should justify the rationale for
    establishing the design space with respect to
    quality attributes such as
    ◦   bioequivalence,
    ◦   stability,
    ◦   Manufacturing
    ◦   robustness etc.
   Formulation adjustment within the design space
    depending on material attributes does not need a
    submission in a regulatory postapproval change.


                                                         12
                               www.drugragulations.org    8
   A set of proven acceptable ranges alone does not
    constitute a design space.
   A combination of proven acceptable ranges
    (PARs) developed from univariate
    experimentation does not constitute a design
    space
   Proven acceptable ranges from only univariate
    experimentation may lack an understanding of
    interactions between the process parameters
    and/or material attributes.

                                                        12
                              www.drugragulations.org    9
   However proven acceptable ranges continue
    to be acceptable from the regulatory
    perspective but are not considered a design
    space.
   The applicant may elect to use proven
    acceptable ranges or design space for
   different aspects of the manufacturing
    process



                                                      13
                            www.drugragulations.org    0
   Outer limits of the design space need not be
    evaluated during process validation studies at
    the commercial scale.
   There is no need to run the qualification
    batches at the outer limits of the design
    space during process validation studies at
    commercial scale.
   The design space should be sufficiently
    explored earlier during development studies.

                                                       13
                             www.drugragulations.org    1
   “If the experimental design is poorly chosen, so
    that the resultant data do not contain much
    information, not much can be extracted, no
    matter how thorough or sophisticated the
    analysis.
   On the other hand, if the experimental design
    is wisely chosen, a great deal of information in
    readily extractable form is usually available,
    and no elaborate analysis may be necessary.
   In fact, in many happy situations all the
    important conclusions are evident from visual
    examination of the data.”


                              www.drugragulations.org   132
Product Profile      Quality Target Product Profile (QTPP)


     CQA’s            Determine “potential” critical quality attributes (CQAs)


Risk Assessments      Link raw material attributes and process parameters to
                       CQAs and perform risk assessment
  Design Space        Develop a design space (optional and not required)


Control Strategy      Design and implement a control strategy

    Continual         Manage product lifecycle, including continual
  Improvement
                       improvement


                                              www.drugragulations.org             133

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Quality by Design : Design Space

  • 1. Design Space Presentation prepared by Drug Regulations – a not for profit organization. Visit www.drugreulations.org for the latest in Pharmaceuticals. www.drugragulations.org 1
  • 2. Product Profile  Quality Target Product Profile (QTPP) CQA’s  Determine “potential” critical quality attributes (CQAs) Risk Assessments  Link raw material attributes and process parameters to CQAs and perform risk assessment Design Space  Develop a design space (optional and not required) Control Strategy  Design and implement a control strategy Continual  Manage product lifecycle, including continual Improvement improvement www.drugragulations.org 2
  • 3. Product Profile CQA’s  This presentation Part IV of the series “QbD for Beginners” covers Risk Assessments basic aspects of Design Space ◦ Design Space ◦ Design of experiments ◦ Models Control Strategy Continual Improvement www.drugragulations.org 3
  • 4. The relationship between the process inputs (material attributes and process parameters) and the critical quality attributes can be described as the design space. www.drugragulations.org 4
  • 5. The multidimensional combination and interaction of input variables (e.g., material attributes) and process parameters that have been demonstrated to provide assurance of quality.  Working within 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 regulatory post approval change process.  Design space is proposed by the applicant and is subject to regulatory assessment and approval (ICH Q8). www.drugragulations.org 5
  • 6. The Multi-dimensional region which encompasses the various combinations of product design, manufacturing process design, manufacturing process operating parameters and raw material quality which produce material of suitable ( defined) quality. www.drugragulations.org 6
  • 7. Critical Quality Attributes Input Materials Output Materials Process Step (Product or Intermediate) Design Space Input Measured Process Parameters Parameters or Attributes Process Control Model Measurements and Controls www.drugragulations.org 7
  • 8. 100.0 2 95.0 90.0 Surface Plot Contour Plot 1.8 Dissolution (%) 1.6 85.0 Dissolution (%) 80.0 1.4 90.0-95.0 75.0 Parameter 2 1.2 70.0 85.0-90.0 65.0 1 80.0-85.0 60.0 75.0-80.0 0.8 55.0 70.0-75.0 0.6 50.0 Design Space 65.0-70.0 2 0.4 60.0-65.0 40 (non-linear) Pa 2 0.2 ram 50 1 er ete et Design Space r1 am 0 60 0 P ar 40 42 44 46 (linear ranges) 48 50 52 54 56 58 60 Parameter 1 • Design space proposed by the applicant • Design space can be described as a mathematical function or simple parameter range • Operation within design space will result in a product meeting the defined quality attributes www.drugragulations.org 8
  • 9. Knowledge Space Design Space: “Multidimensional Design Space combination and interaction of input variables (e.g., material attributes) and process parameters that have been NOR demonstrated to provide assurance of quality.” CQA Knowledge Space: “A summary of all process knowledge obtained during product development.” www.drugragulations.org 9
  • 10. There are no regulatory requirements to have a Design Space www.drugragulations.org 10
  • 11. Design space can illustrate understanding of parameter interactions and provides manufacturing flexibility  Proven acceptable range alone is not a design space  Design space should be verified and operational at full scale  No requirement to develop a design space at the full manufacturing scale www.drugragulations.org 11
  • 12. A design space can be described in terms of ranges of material attributes and process parameters.  It can also be described through more complex mathematical relationships.  It is possible to describe a design space as a time dependent function (e.g., temperature and pressure cycle of a lyophilisation cycle), or  As a combination of variables such as components of a multivariate model. www.drugragulations.org 12
  • 13. Design Space www.drugragulations.org 13
  • 14. Scaling factors can also be included if the design space is intended to span multiple operational scales.  Analysis of historical data can contribute to the establishment of a design space.  Regardless of how a design space is developed, it is expected that operation within the design space will result in a product meeting the defined quality. www.drugragulations.org 14
  • 15. Independent design spaces can be established for one or more unit operations, or  Single design space that spans multiple operations can also be established.  A separate design space for each unit operation is often simpler to develop.  However a design space that spans the entire process can provide more operational flexibility.  For example, in the case of a drug product that undergoes degradation in solution before lyophilisation, the design space to control the extent of degradation (e.g., concentration, time, temperature) could be expressed for each unit operation or as a sum over all unit operations. www.drugragulations.org 15
  • 16. Identify Q T P P Identify C Q A Risk Assessment Define product design space Define process design space Risk Assessment Refine process design space Process Characterization Define Control strategy Risk Assessment Process Validation Process Monitoring www.drugragulations.org 16
  • 17. Consider QTPP in establishing the Design Space  Initial determination of CQAs  Assess prior knowledge to understand variables and their impact  Scientific principles & historical experience  Perform initial risk assessment of manufacturing process relative to CQAs to identify the high risk manufacturing steps (->CPPs)  Conduct Design of Experiments (DoE)  Evaluate experimental data  Conduct additional experiments/analyses as needed www.drugragulations.org 17
  • 18. First-principles approach ◦ Combination of experimental data and mechanistic knowledge of chemistry, physics, and engineering to model and predict performance  Statistically designed experiments (DOEs) ◦ Efficient method for determining impact of multiple parameters and their interactions  Scale-up correlation ◦ A semi-empirical approach to translate operating conditions between different scales or pieces of equipment www.drugragulations.org 18
  • 19. The risk assessment and process development experiments can lead to an understanding of the linkage and effect of process parameters and material attributes on product CQAs and  Also help identify the variables and their ranges within which consistent quality can be achieved.  These process parameters and material attributes can thus be selected for inclusion in the design space. www.drugragulations.org 19
  • 20. Prior knowledge may include :  Internal knowledge from development and manufacturing  External knowledge: scientific and technical publications (including literature and peer-reviewed publications)  Citation in filing: regulatory filings, internal company report or notebook, literature reference  No citation necessary if well known and accepted by scientific community www.drugragulations.org 20
  • 21. Risk assessment is based on prior knowledge and relevant experience for the product and manufacturing process  Gaps in knowledge could be addressed by further experimentation  Assignments of risk level must be appropriately justified  Risk assessments/control will iterate as relevant new information becomes available  Final iteration shows control of risks to an acceptable level www.drugragulations.org 21
  • 22. ◦ Design space could include critical and non-critical parameters  Critical parameter ranges/model are considered a regulatory commitment and non-critical parameter ranges support the review of the filing  Critical parameter changes within design space are handled by the Quality System and changes outside the design space need appropriate regulatory notification ◦ Non-critical parameters would be managed by Quality System www.drugragulations.org 22
  • 23. DOE useful tool in development of a DS but not the only one ◦ 1st Principles models  DS may cover one, or multiple unit operation(needs to be clear in the dossier)  Not all unit operations must have a DS  Unit operations without a DS will obviously not achieve the regulatory benefits (ie, ability to move within DS) www.drugragulations.org 23
  • 24. DS is usually developed at lab scale  There is no need to perform full DOEs at full scale to confirm the DS at full scale.  Good understanding of scale up phenomena is needed, some parameters may be scale independent (needs to be justified)  Scale up factors could be used to reduce concern about moving within DS at scale  Experiments within the DS at full scale could also be used to reduce the same concern.  Another option is have additional monitoring controls applied when there is a change within the DS to ensure that the DS is still valid and then relaxation to a less stringent control strategy. www.drugragulations.org 24
  • 25. DS needs to be complemented by an appropriate control strategy  Critical process parameters remain critical even if  controlled,  CQAs: appropriate specs need to be set, even if not tested routinely  Release based on CQAs and control of process parameters is possible if satisfactorily demonstrated ( e.g. dissolution release based on particle size control, and disintegration test) www.drugragulations.org 25
  • 26. One-factor-at-a-time (the classical approach)  Designed experiments (DOE) www.drugragulations.org 26
  • 27. One-factor-at-a-time ◦ Procedure (2 level example)  Run all factors at one condition  Repeat, changing condition of one factor  Continuing to hold that factor at that condition, rerun with another factor at its second condition  Repeat until all factors at their optimum conditions ◦ Slow, expensive: many tests ◦ Can miss interactions! www.drugragulations.org 27
  • 28. Process: Yield = f(temperature, pressure) 50% yield 30% yield Max yield: 50% at 78 C, 130 psi? www.drugragulations.org 28
  • 29. A better view of the maximum yield! Optimized yield is over 85% Process: Yield = f(temperature, pressure) www.drugragulations.org 29
  • 31. Multiple-Factors-at-a-Time, DOE ◦ Full Factorials ◦ Fractional Factorials ◦ Plackett – Burman designs ◦ Central Composite designs www.drugragulations.org 31
  • 32. DOE is defined as “a structured analysis wherein inputs are changed and differences or variations in outputs are measured to determine the magnitude of the effect of each of the inputs or combination of inputs.”  Full factorial example: Dependent Independent Variable Variable (Controlling Factors) (Response) Run Factor X1 Factor X2 Factor Y1 1 High High Output1 2 Low High Output2 3 High Low Output3 4 Low Low Output4 www.drugragulations.org 32
  • 33. (1) Choose experimental design (e.g., full factorial, d-optimal) (2) Conduct randomized experiments Experiment Factor A Factor B Factor C 1 + - - A 2 - + - 3 + + + B C 4 + - + (3) Analyze data (4) Create multidimensional surface model (for optimization or control) www.minitab.com www.drugragulations.org 33
  • 34. Several families  n = number of Factor tested and L : level/factor  Semi Factorial Design : the lowest number of experiments required : 2n-k  Used for a first screening of mains factors and at least single interactions  Used for demonstration of a Proven Acceptable Range (PAR) or Design Space ◦ Don‟t be afraid by the number of factor.  Factorial Design : higher number of experiments : 2n  For both Design, only two levels (L = 2) + eventual central point(s), Models will always be linear.  Response Surface Model : higher number of experiments : Ln. Non linear models. The number of experiments can be decreased by historical methods or by computer optimisation (D Optimal). ◦ Used for optimisation/ modeling of a process ◦ Used for searching the „‟ edge of failure‟‟  Mixture : RSM + constraint (sum of component = fixed value)  Used in chemistry, formulation,…  Combined : Mixture + (semi) Factorial or RSM  Used for combines mixture/process such as formulation (excipents) and freeze drying conditions. 34
  • 35. The kind of question to answer must be understood : ◦ Critical parameters ◦ Interactions ◦ Optimisation ◦ Demonstration of Proven Acceptable Range ◦ Modeling  The experiments are planned before starting  Apparently a high number of experiments, more work, more time, more money.  In reality, far less experiments (semi factorial or reduction for RSM) to obtain far less valuables results. Allow a better planning of experiments including Analytical. 35
  • 36. Randomization, blocking and replication are the three basic principles of statistical experimental design.  By properly randomizing the experiment, the effects of uncontrollable factors that may be present can be “averaged out”.  Blocking is the arrangement of experimental units into groups (blocks) that are similar to one another.  Blocking reduces known but irrelevant sources of variation between groups and thus allows greater precision in the estimation of the source of variation under study.  Replication allows the estimation of the pure experimental error for determining whether observed differences in the data are really statistically different www.drugragulations.org 36
  • 37. ANOVA results should accompany all DOE data analysis, especially if conclusions concerning the significance of the model terms are discussed.  For all DOE data analysis, the commonly used alpha of 0.05 is chosen to differentiate between significant and non significant factors.  It is important that any experimental design has sufficient power to ensure that the conclusions drawn are meaningful.  Power can be estimated by calculating the signal to noise ratio.  If the power is lower than the desired level, some remedies can be employed to increase the power.  For example, by adding more runs, increasing the signal or decreasing the system noise.  ICH Points to Consider document for guidance on the level of DOE documentation recommended for regulatory submissions. www.drugragulations.org 37
  • 38. A design space can be updated over the lifecycle as additional knowledge is gained.  Risk assessments, as part of the risk management process, help steer the focus of development studies and define the design space.  Operating within the design space is part of the control strategy.  The design space associated with the control strategy ensures that the manufacturing process produces a product that meets ◦ The Quality Target Product Profile (QTPP) and ◦ Critical Quality Attributes (CQAs). www.drugragulations.org 38
  • 39. Since design spaces are typically developed at small scale, an effective control strategy helps manage potential residual risk after development and implementation.  When developing a design space for a single-unit operation, the context of the overall manufacturing process can be considered, particularly immediate upstream and downstream steps that could interact with that unit operation.  Potential linkages to CQAs should be evaluated in design space development. www.drugragulations.org 39
  • 40. In developing design spaces for existing products, multivariate models can be used for retrospective evaluation of historical production data.  The level of variability present in the historical data will influence the ability to develop a design space, and additional studies might be appropriate. www.drugragulations.org 40
  • 41. Design spaces can be based on ◦ scientific first principles and/or ◦ empirical models.  An appropriate statistical design of experiments incorporates a level of confidence that applies to the entire design space, including the edges of an approved design space. www.drugragulations.org 41
  • 42. However, when operating the process near the edges of the design space, the risk of excursions from the design space could be higher because of normal process variation (common cause variation). www.drugragulations.org 42
  • 43. The control strategy helps manage residual risk associated with the chosen point of operation within the design space.  When changes are made (e.g., process, equipment, raw material suppliers), results of risk review can provide information regarding additional studies and/or testing that might verify the continued applicability of the design space and associated manufacturing steps after the change. www.drugragulations.org 43
  • 44. Capturing development knowledge and understanding contributes to design space implementation and continual improvement.  Different approaches can be considered when implementing a design space (e.g., process ranges, mathematical expressions, or feedback controls to adjust parameters during processing (see also Figure 1d in ICH Q8(R2)).  The chosen approach would be reflected in the control strategy to assure the inputs and process stay within the design space. www.drugragulations.org 44
  • 45. Although the entire design space does not have to be reestablished (e.g., DoE) at commercial scale, design spaces should be initially verified as suitable prior to commercial manufacturing.  Design space verification should not be confused with process validation.  However, it might be possible to conduct verification studies of the performance of the design space scale-dependent parameters as part of process validation. www.drugragulations.org 45
  • 46. Design space verification includes monitoring or testing of CQAs that are influenced by scale- dependent parameters.  Additional verification of a design space might be triggered by changes (e.g., site, scale, or equipment).  Additional verification is typically guided by the results of risk assessments of the potential impacts of the change(s) on design space. www.drugragulations.org 46
  • 47. A risk-based approach can be applied to determine the design of any appropriate studies for assessment of the suitability of a design space across different scales.  Prior knowledge and first principles, including simulation models and equipment scale-up factors, can be used to predict scale-independent parameters.  Experimental studies could help verify these predictions. www.drugragulations.org 47
  • 48. Some aspects of the design space that could be considered for inclusion in the regulatory submission:  The design space description, including critical and other relevant parameters.  The design space can be presented as ranges of material inputs and process parameters, graphical representations, or through more complex mathematical relationships.  The relationship between the inputs (e.g., material attributes and/or process parameters) and the CQAs, including an understanding of the interactions among the variables. www.drugragulations.org 48
  • 49. Data supporting the design space, such as prior knowledge, conclusions from risk assessments as part of QRM, and experimental studies with supporting data, design assumptions, data analysis, and models.  The relationship between the proposed design space and other unit operations or process steps.  Results and conclusions of the studies, if any, of a design space across different scales.  Justification that the control strategy ensures that the manufacturing process is maintained within the boundaries defined by the design space. www.drugragulations.org 49
  • 50. The control strategy used for implementation of a design space in production depends on the capabilities of the manufacturing site.  The batch records reflect the control strategy used.  For example, if a mathematical expression is used for determining a process parameter or a CQA, the batch record would include the input values for variables and the calculated result. www.drugragulations.org 50
  • 51. As part of the technology transfer of a design space to a site and throughout the lifecycle, it is important to share the knowledge gained during development and implementation that is relevant for using that design space both on the manufacturing floor and under the PQS of the company or site.  This knowledge can include results of risk assessments, assumptions based on prior knowledge, and statistical design considerations.  Linkages among the design space, control strategy, CQA, and QTPP are an important part of this shared knowledge. www.drugragulations.org 51
  • 52. Each company can decide on the approach used to capture design space information and movements within the design space under the applicable PQS, including additional data gained through manufacturing experience with the design space.  In the case of changes to an approved design space, appropriate filings should be made to meet regional regulatory requirements. www.drugragulations.org 52
  • 53. Movement within the approved design space, as defined in the ICH Q8(R2) glossary, does not call for a regulatory filing.  For movement outside the design space, the use of risk assessment could be helpful in determining the impact of the change on quality, safety, and efficacy and the appropriate regulatory filing strategy, in accordance with regional requirements. www.drugragulations.org 53
  • 54. A model is a simplified representation of a system using mathematical terms.  Models can enhance scientific understanding and  Possibly predict the behavior of a system under a set of conditions.  Mathematical models can be used at every stage of development and manufacturing. www.drugragulations.org 54
  • 55. They can be derived from ◦ first principles reflecting physical laws (such as mass balance, energy balance, and heat transfer relations), or ◦ From data, or ◦ From a combination of the two. www.drugragulations.org 55
  • 56. There are many types of models.  The selected one will depend on ◦ The existing knowledge about the system, ◦ The data available, and ◦ The objective of the study. www.drugragulations.org 56
  • 57. Models can be categorized in multiple ways.  The categorization approaches are intended to facilitate the use of models across the lifecycle, including ◦ Development, ◦ Manufacturing, ◦ Control, and ◦ Regulatory processes. www.drugragulations.org 57
  • 58. For the purposes of regulatory submissions, an important factor to consider is the model‟s contribution in assuring the quality of the product.  The level of oversight should be commensurate with the level of risk associated with the use of the specific model. www.drugragulations.org 58
  • 59. Low-Impact Models: These models are typically used to support ◦ Product and/or ◦ Process development ◦ (e.g., formulation optimization). www.drugragulations.org 59
  • 60. Medium-Impact Models: Such models can be useful in assuring quality of the product.  However these models are not the sole indicators of product quality  (e.g., most design space models, many in- process controls). www.drugragulations.org 60
  • 61. High-Impact Models: A model can be considered high impact if prediction from the model is a significant indicator of quality of the product.  (e.g., a chemometric model for product assay, a surrogate model for dissolution). www.drugragulations.org 61
  • 62. For the purpose of implementation, models can also be categorized on the basis of the intended outcome of the model.  Within each of these categories, models can be further classified as ◦ Low, ◦ Medium or ◦ High,  Classification based on their impact in assuring product quality. www.drugragulations.org 62
  • 63. Models for supporting process design: This category of models includes (but is not limited to) models for ◦ Formulation optimization, ◦ Process optimization  (e.g., reaction kinetics model), ◦ Design space determination, and ◦ Scale-up. www.drugragulations.org 63
  • 64. Models for supporting process design:  Models within this category can have different levels of impact.  For example, a model for design space determination would generally be considered a medium-impact model,  While a model for formulation optimization would be considered a low-impact model. www.drugragulations.org 64
  • 65. Models for supporting analytical procedures: In general, this category includes empirical (i.e., chemometric) models based on data generated by various Process Analytical Technology (PAT)-based methods. www.drugragulations.org 65
  • 66. Models for supporting analytical procedures:  A calibration model associated with a near infrared (NIR)-based method.  Models for supporting analytical procedures can have various impacts depending on the use of the analytical method.  For example, if the method is used for release testing, then the model should be high- impact. www.drugragulations.org 66
  • 67. Models for process monitoring and control: ◦ Univariate Statistical Process Control (SPC) or ◦ Multivariate Statistical Process Control (MSPC)- based models:  These models are used to detect special cause variability;  The model is usually derived and the limits are determined using batches manufactured within the target conditions. www.drugragulations.org 67
  • 68. Models for process monitoring and control:  If an MSPC model is used for continuous process verification along with a traditional method for release testing, then the MSPC model would likely be classified as a medium-impact model. www.drugragulations.org 68
  • 69. Models for process monitoring and control:  However, if an MSPC model is used to support a surrogate for a traditional release testing method in an RTRT approach, then the model would likely be classified as a high-impact model. www.drugragulations.org 69
  • 70. Models used for process control (e.g., feed forward or feedback).  Data-driven models should be developed through appropriately designed experiments.  These models are typically medium-impact or high-impact.  For example, a feed forward model to adjust compression parameters on the basis of incoming material attributes could be classified as a medium-impact model. www.drugragulations.org 70
  • 71. Sequential steps  Steps can be repeated to impart an iterative nature to this process.  Overall steps are given in following slides: www.drugragulations.org 71
  • 72. 1. Defining the purpose of the model. 2. Deciding on the type of modeling approach. ◦ (e.g. mechanistic or empirical) and ◦ Possible experimental/sampling methodology to be used to support the model development. www.drugragulations.org 72
  • 73. 3. Selecting variables for the model; this is typically based on ◦ Risk assessment, ◦ Underlying physicochemical phenomena, ◦ Inherent process knowledge, and ◦ Prior experience. www.drugragulations.org 73
  • 74. 4. Understanding the limitations of the model assumptions to: ◦ Correctly design any appropriate experiments; ◦ Interpret the model results; and ◦ Include appropriate risk-reduction strategies. www.drugragulations.org 74
  • 75. 5. Collecting experimental data to support model development. ◦ These data can be collected at  Laboratory,  Pilot, or  Commercial scale, (depending on the nature of the model. ) ◦ It is important to ensure that variable ranges evaluated during model development are representative of conditions that would be expected during operation. www.drugragulations.org 75
  • 76. 6. Developing model equations estimating parameters, based on a scientific understanding of the process and collected experimental data. www.drugragulations.org 76
  • 77. 7. Validating the model, as appropriate. 8. In certain cases, evaluating the impact of uncertainty in model prediction on product quality. ◦ If appropriate, defining an approach to reduce associated residual risk  (e.g., by incorporating appropriate control strategies (this can apply to high-impact and medium-impact models)). www.drugragulations.org 77
  • 78. 9. Documenting the outcome of model. ◦ Development ◦ Assumptions  Developing plans for verification and update of the model throughout the lifecycle of the product.  The level of documentation would be dependent on the impact of the model www.drugragulations.org 78
  • 79. Model validation is an essential part of model development and implementation.  Once a model is developed and implemented, verification continues throughout the lifecycle of the product. www.drugragulations.org 79
  • 80. In the case of well-established first principles- driven models, prior knowledge can be leveraged to support model validation and verification, if applicable.  The following elements can be considered for model validation and verification and generally are appropriate for high-impact models  The applicability of the elements listed below for medium-impact or low-impact models can be considered on a case-by-case basis. www.drugragulations.org 80
  • 81. Acceptance criteria relevant to the purpose and to its expected performance.  In setting the acceptance criteria, variability in sampling procedure (e.g., for blending) could also be considered.  In situations where the model is to be used to support a surrogate for a traditional release testing method, the accuracy of the model performance versus the reference method could be considered. www.drugragulations.org 81
  • 82. For example, a multivariate model (e.g. a partial least squares (PLS) model), when appropriate, can be used as a surrogate for traditional dissolution testing.  In this case, the PLS model should be developed in terms of in-process parameters and material attributes and can be used to predict dissolution. www.drugragulations.org 82
  • 83. One of the ways to validate and verify model performance in this case would be to compare accuracy of prediction of the PLS model with the reference method (e.g., a traditional dissolution method). www.drugragulations.org 83
  • 84. Comparison of the accuracy of calibration versus the accuracy of prediction.  This can often be approached through internal cross-validation techniques using the same data as the calibration data set. www.drugragulations.org 84
  • 85. It can be beneficial to verify the prediction accuracy of the model by parallel testing with the reference method during the initial stage of model implementation.  This testing can be repeated throughout the lifecycle, as appropriate.  If models are used to support a design space at commercial scale or are part of the control strategy, it is important to verify the model at commercial scale. ◦ If a calibration model associated with an NIR-based method is developed at the laboratory scale and the method is then transferred to and used in commercial scale. www.drugragulations.org 85
  • 86. In addition, the data sets used for calibration, internal validation, and external validation should take into account the variability anticipated in future routine production ◦ (e.g., a change in the source of raw material that might impact NIR prediction).  Low-impact models typically do not call for verification. www.drugragulations.org 86
  • 87. Approaches for model verification can be documented according to the PQS of the company and can include the following: ◦ A risk-based frequency of comparing the model‟s prediction with that of the reference method, ◦ Triggers for model updates (e.g., because of changes in raw materials or equipment), ◦ Procedures for handling model-predicted Out of Specification (OOS) results, ◦ Periodic evaluations, and approaches to model recalibration www.drugragulations.org 87
  • 88. The level of detail for describing a model in a regulatory submission is dependent on the impact of its implementation in assuring the quality of the product.  For the various types of models, the applicant can consider including: www.drugragulations.org 88
  • 89. Low-Impact Models: A discussion of how the models were used to make decisions during process development. www.drugragulations.org 89
  • 90. Medium-Impact Models: ◦ Model assumptions, ◦ A tabular or graphical summary of model inputs and outputs, ◦ Relevant model equations (e.g., for mechanistic models), ◦ Statistical analysis where appropriate, ◦ a comparison of model prediction with measured data, and ◦ A discussion of how the other elements in the control strategy help to mitigate uncertainty in the model, if appropriate. www.drugragulations.org 90
  • 91. High-Impact Models: Data and/or prior knowledge (e.g., for established first principles-driven models) such as ◦ Model assumptions, ◦ Appropriateness of the sample size, number and distribution of samples, ◦ Data pretreatment, ◦ Justification for variable selection, ◦ Model inputs and outputs, ◦ Model equations, ◦ Statistical analysis of data showing fit and prediction ability, ◦ Rationale for setting of model acceptance criteria, ◦ Model validation (internal and external), and ◦ A general discussion of approaches for model verification during the lifecycle. www.drugragulations.org 91
  • 92. Rittinger’s law: The work required in crushing is proportional to the new surface created. Where: P=power required, dm/dt=feed rate to crusher, Dsb = ave diameter before crushing, DSQ=ave after crushing, Kr=Rittinger’s coef. Kick’s law: the work required for crushing a given mass of material is constant for the same reduction ratio, that is the ratio of the initial particle size to the finial particle size Kk=Kick’s coef.
  • 93. For fine grains, the Characteristic region boundary between the characteristic Blender head space region and the remaining powder bed is parabolic in shape n m o m The powder bed Vr rV V r 1 below the boundary r 1 rotates with the mixer as a solid as fraction mixed body. n f rm rf o f rm1 r 1
  • 94. 0.40 Avicel® PH-200 compacts VFS Speed: 200 rpm 0.35 HFS Speed: 30 rpm Roll Pressure: 6560 lb/in Slope of NIR Spectrum 0.30 Roll Speed (RPM) 0.25 y = 0.3672x + 0.1754 4 5 6 R2 = 0.9899 7 8 9 0.20 10 11 12 0.15 0.0 0.1 0.2 0.3 0.4 0.5 0.6 20 Force at break/Thickness/Width (N/mm2) 18 Avicel® PH-200 compacts  The strength is a 16 VFS Speed: 194 - 197 rpm HFS Speed: 29 - 30 rpm Roll Gap: 0.031 - 0.038" linear function of the 14 Roll Pressure: 6551 lb/in Force at break (N) 12 density which is 10 monitored by NIR 8 y = 21.54e -0.4493x  Semi Empirically 6 R2 = 0.9884 4 F=(SNIR-0.17)/0.37 2 0 4 5 6 7 8 9 10 11 12 Roll Speed (RPM)
  • 95. Avicel® PH-200 Milled Compacts 1000 Increaing Roll Speed Day1 Day2 800 Particle Size ( m) d90 600 400 d50 200 d10 0 3 4 5 6 7 8 9 10 11 12 13 Roll Speed (rpm) Avicel® PH-200 Milled Compacts 1200 Increaing Roll Speed  The particle sizes d90 Day1 of the milled 1000 Day2 material is also 800 Particle Size ( m) manifest in the 600 d50 slope of the NIR signal (as 400 d10 predicted) 200 0 2.0 2.5 3.0 3.5 4.0 4.5 5.0 5.5 6.0 1 / Slope NIR Spectrum
  • 96. Optimum Conditions (u,v)= *(u,v) 0 Equilibrium Moisture Content SIZE M=M0-Kt M=M0’exp(-K’t) 18 0.600 GRANULATION TIME 16 0.550 14 Moisture Content (% w/w) Mean Particle Size (mm) 12 0.500 Moisture Content Particle Size 10 0.450 8 6 0.400 4 0.350 2 0 0.300 0 20 40 60 80 100 Elapsed Time (min)
  • 97. Funicular Modeling Wet Granulation Pendular Over Wetting Droplet Capillary Drying
  • 98. 0.0010 X1=110 g H13 (1 min) (=X3) H15 (3.5 min) X2=255 rpm NIR Treated Response H14 (6 min) 0.0008 610 m 410 m Slope 320 m 0.0006 0.0004 MIXING SPRAYING WET MASSING 0.0002 0 100 200 300 400 500 600 Process time (s)
  • 99. [Kunii and Levenspiel, Fluidization Engineeri [Kunii and Levenspiel, Fluidization Engineering, Pub. Krieger, pg. 424-428,1977] 180 65 Evaporative Moisture Content Temperature 63 160 Q Qo Kt 61 Critical 140 moisture Temperature (°C) 59 MM55 Reading T 57 120 55 100 53 80 Diffusive 51 MM55 Q Q Q'ok EXP( k' t) 49 60 47 40 45 0 5 10 15 20 25 30 Drying Time (min) K.R. Morris, S.L. Nail, G.E. Peck, S.R. Byrn, U.J. Griesser, J.G. Stowell, S.-J. Hwang, K. Park Pharm Sci Tech Today 1 6 235–245 (1998).
  • 100. 235 NIR Monitor (Arbitrary Values) 215 195 175 155 135 115 Conventional Drying Fast Drying 95 75 0.00 5.00 10.00 15.00 20.00 25.00 Time (min) Morris et.al., Drug Dev. Ind. Pharm., 26 (9):985-
  • 101. 60.00 240.0 Average Exhaust Temp 55.00 220.0 MM55 Gauge Reading 200.0 50.00 180.0 45.00 160.0 40.00 140.0 Active Melting Temp 35.00 120.0 30.00 100.0 80.0 25.00 60.0 20.00 0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 Elapsed Drying Time (min) 120 Batch 018 sub1 Batch 018 sub2 Batch 019 sub1 Batch 019 sub2 Batch 020 sub1 Batch 021 sub1 Batch 021 sub2 Average % Release 100 80 60 40 Baseline Data 20 Temp Excursion 0 0 20 40 60 80 100 120 Time (min)
  • 102. WHOLE TABS HALF TABS QUARTER TABS Active 1 Active 2 Active 1 Active 2 Active 1 Active 2 MEAN 101.9 100.9 101.8 99.6 102.1 100.5 SD 0.7 1.6 1.4 2.8 2.4 5.1 CV (%) 0.7 1.6 1.3 2.8 2.3 5.1 CU for constant size portions of tablets must be larger than for the whole, so in spec using real time monitoring of “part” of the tablets means in spec for the whole tablet CVP CVT T. Li, et. al., in press Pharm. Res. BioMed Anal.
  • 103. HPMC and Sulfanilamide Calculations (Peak Height) 0.4 0.35 Absorbance (log(1/R)) 0.3 HPMC Sulfanilamide 0.25 0.2 0.15 0 30 60 90 120 150 Elapsed Time (min) 200 700 100 500 Sulfanilamide Gauge 0 M oisture Gauge Sulfanilam ide 300 Moisture -100 100 -200 -100 -300 -400 -300 0 20 40 60 80 100 120 140 160 Elapsed Time (min)
  • 104. These principles and techniques are applicable to batch and continuous processing and may be linked by multi-variate (chemometric) methods after univariate conformation.  Ultimately this give us the ability to understand how development variables interact to influence the final product and to design in the quality 10 www.drugragulations.org 4
  • 105. Quality by Design for ANDAs: An Example for Immediate-Release Dosage Forms Published by FDA www.drugragulations.org 105
  • 106. Aqueous 0.1 N HCL 0.015 mg/ml solubility as a pH 4.5 buffer 0.015 mg/ml function of pH: pH 6.8 buffer 0.015 mg/ml Hyroscopicity Acetriptan Form III is non-hygroscopic and requires no special protection from humidity during handling, shipping or storage Density (Bulk, • Bulk density: 0.27 g/cc Tapped, and • Tapped density: 0.39 g/cc True) and • True density: 0.55 g/cc Flowability: • The flow function coefficient (ffc) was 2.95 and the Hausner ratio was 1.44 which both indicate poor flow properties. Chemical • pKa: Acetriptan is a weak base with a pKa of 9.2. properties • Overall, acetriptan is susceptible to dry heat, UV light and oxidative degradation. Biological • Partition coefficient: Log P 3.55 (25 °C, pH 6.8) properties • Caco-2 permeability: 34 × 10-6 cm/s. Therefore, acetriptan is highly permeable. • BCS Class II compound (low solubility and high permeability) www.drugragulations.org 106
  • 107. Drug Substance Attributes Drug Solid PSD Hygrosc Solubil Mois Residual Process Chemi Flow Product State opicity ity ture Solvent Impurit cal prop Cont CQA Form ies stabili ent ty Assay Low Med Low Low Low Low Low High Med CU Low High Low Low Low Low Low Low High Dissolution High High Low High Low Low Low Low Low Degradation Med Low Low Low Low Low Low High Low products www.drugragulations.org 107
  • 108. Component Function Unit Unit ( mg/tablet) ( % W/W) Acetriptan, USP Active 20 10 Lactose Monohydrate, NF Filler 64-86 32-43 Microcrystalline Cellulose Filler 72-92 36-46 (MCC), NF Croscarmellose Sodium Disintegrant 2-10 1-5 (CCS), NF Magnesium Stearate, NF* Lubricant 2-6 1-3 Talc, NF Glidant/Lubricant 1-10 0.5-5 Total tablet weight 200 100 www.drugragulations.org 108
  • 109. Formulation Variables Drug product DS PSD MCC/ CCS Level Talc Level Mag Stearate CQA Lactose Level ratios Assay Medium Medium Low Low Low Content High High Low Low Low Uniformity Dissolution High Medium High Low High Degradation Low Low Low Low Medium Products www.drugragulations.org 109
  • 110. Formulation development focused on evaluation of the high risk formulation variables as identified in the initial risk assessment shown earlier.  The development was conducted in two stages.  The first formulation study evaluated the impact of the drug substance particle size distribution, the MCC/Lactose ratio and the disintegrant level on the drug product CQAs.  The second formulation study was conducted to understand the impact of extragranular magnesium stearate and talc level in the formulation on product quality and manufacturability.  Formulation development studies were conducted at laboratory scale (1.0 kg, 5,000 units). www.drugragulations.org 110
  • 111. Goal of Formulation Development Study #1  Select the MCC/Lactose ratio and  Disintegrant level and  To understand if there was any interaction of these variables with drug substance particle size distribution.  This study also sought to establish the robustness of the proposed formulation.  A 2³ full factorial Design of Experiments (DOE) with three center points was used to study the impact of these three formulation factors on the response variables. www.drugragulations.org 111
  • 112. Process step Equipment Pre-Roller Compaction 4 qt V-blender Blending and Lubrication o 250 revolutions for blending (10 min at 25 rpm) Alexanderwerk10 WP120 with 25 mm roller width and 120 mm roller diameter o Roller surface: Knurled Roller Compaction and o Roller pressure: 50 bar Integrated Milling o Roller gap: 2 mm o Roller speed: 8 rpm o Mill speed: 60 rpm o Coarse screen orifice size: 2.0 mm o Mill screen orifice size: 1.0 mm Final Blending and 4 qt V-blender Lubrication o 100 revolutions for granule and talc blending (4 min at 25 rpm) o 75 revolutions for lubrication (3 min at 25 rpm) 16-station rotary press (2 stations used) o 8 mm standard round concave tools Tablet Compression o Press speed: 20 rpm o Compression force: 5-15 kN o Pre-compression force: 1 kN www.drugragulations.org 112
  • 113. Factors : Formulation Variables Levels -1 0 +1 A Drug substance PSD (d90, μm) 10 20 30 B Disintegrant (%) 1 3 5 C % MCC in MCC/Lactose combination 33.3 50 66.7 www.drugragulations.org 113
  • 114. Responses Goal Acceptable Range Y1 Dissolution at 30 min (%) (with hardness of 12.0 kP) Maximize ≥ 80% Y2 Disintegration time (min) (with hardness of 12.0 kP) Minimize < 5 min Y3 Tablet content uniformity (% RSD) Minimize % RSD < 5% Y4 Assay (% w/w) Target at 100 % 95.0 to 105.0 w/w Y5 Powder blend flow function coefficient ( ffc) Maximize >6 Y6 Tablet Hardness @ 5 kN ( kP ) Maximize > 5 kP Y7 Tablet Hardness @ 10 kN ( kP ) Maximize > 9 kP Y8 Tablet Hardness @ 15 kN ( kp ) Maximize > 12 kP Y9 Friability@ 5 kN ( kp ) Maximize <1% Y10 Friability@ 10 kN ( kp ) Maximize <1% Y11 friability@ 15 kN ( kp ) Maximize <1% Y12 Degradation products (%) (observed at 3 months, 40 Minimize ACE12345: NMT 0.5% °C/75% RH) Any unknown impurity: NMT 0.2% Total impurities: NMT 1.0% www.drugragulations.org 114
  • 115. A B C Y1 Y3 Y5 Y7 Batch DS PSD Disintegra % MCC Dissolution Content Ffc Tablet No nt level in MCC/ in Uniformity Value Hardness Lactose 30 min @ 10 kN Mix (d90, μm) ( %) (%) (%) ( % RSD ) -- (kP) 1 30 1 66.7 76.0 3.8 7.56 12.5 2 30 5 66.7 84.0 4.0 7.25 13.2 3 20 3 50.0 91.0 4.0 6.62 10.6 4 20 3 50.0 89.4 3.9 6.66 10.9 5 30 1 33.3 77.0 2.9 8.46 8.3 6 10 5 66.7 99.0 5.1 4.77 12.9 7 10 1 66.7 99.0 5.0 4.97 13.5 8 20 3 50.0 92.0 4.1 6.46 11.3 9 30 5 33.3 86.0 3.2 8.46 8.6 10 10 1 33.3 99.5 4.1 6.16 9.1 11 10 5 33.3 98.7 4.0 6.09 9.1 www.drugragulations.org 115
  • 116. Initially, dissolution was tested using the FDA- recommended method.  All batches exhibited rapid and comparable dissolution (> 90% dissolved in 30 min) to the RLD.  All batches were then retested using the in-house dissolution method .  Results are presented in earlier table.  Since center points were included in the DOE, the significance of the curvature effect was tested using an adjusted model.  The Analysis of Variance (ANOVA) results are presented in next table www.drugragulations.org 116
  • 117. Source Sum of df Mean F value P value Comme squares square nts Model 742.19 3 247.40 242.94 < 0.0001 Significant A- Drug Substance PSD (d90, μm) 699.8 1 699.78 657.72 < 0.0001 Significant B- Disintegrant ( % ) 32.81 1 32.81 32.21 0.0013 Significant AB – Interaction 39.61 1 39.61 38.89 0.0008 Significant Curvature 1.77 1 1.77 1.74 0.2358 Not Significant Residual 6.11 6 1.02 --- ----- ---- Lack of fit 2.67 4 0.67 0.39 0.8090 Not Significant Pure error 3.44 2 1.72 ---- ---- ------ Total 750.07 10 --- ---- ----- ----- www.drugragulations.org 117
  • 118. The curvature effect was not significant for dissolution;  Therefore, the factorial model coefficients were fit using all of the data (including center points).  As shown in ANOVA results of the unadjusted model (next slide), the significant factors affecting tablet dissolution were  A (drug substance PSD),  B (disintegrant level) and  AB (an interaction between drug substance PSD and the intragranular disintegrant level). www.drugragulations.org 118
  • 119. Source Sum of df Mean F value P value Comme squares square nts Model 742.19 3 247.40 219.84 < 0.0001 Significant A- Drug Substance PSD (d90, μm) 699.8 1 699.78 595.19 < 0.0001 Significant B- Disintegrant ( % ) 32.81 1 32.81 29.15 0.0010 Significant AB – Interaction 39.61 1 39.61 35.19 0.0006 Significant Residual 7.88 7 1.13 --- ----- ---- Lack of fit 4.44 5 0.89 0.52 0.7618 Not Significant Pure error 3.44 2 1.72 ---- ---- ------ Total 750.07 10 --- ---- ----- ----- www.drugragulations.org 119
  • 120. Under Quality by Design, establishing a design space or using real-time release testing is not necessarily expected (ICH Q8(R2)). 12 www.drugragulations.org 0
  • 121. It is not necessary to study multivariate interactions of all parameters to develop a design space.  The applicant should justify the choice of material attributes and parameters for multivariate experimentation based on risk assessment and desired operational flexibility. 12 www.drugragulations.org 1
  • 122. When appropriately justified design space can be applicable to scale-up.  Design space can be applicable to a site change.  It is possible to justify a site change using a site independent design space based on a demonstrated understanding of the robustness of the process and an in depth consideration of site specific factors (e.g., equipment, personnel, utilities, manufacturing environment, and equipment). 12 www.drugragulations.org 2
  • 123. There are region specific regulatory requirements associated with site changes that need to be followed.  Design space can be developed for a single unit operations or across a series of unit operations. 12 www.drugragulations.org 3
  • 124. It is possible to develop a design space for existing products.  Manufacturing data and process knowledge can be used to support a design space for existing products.  Relevant information should be utilized from ◦ Commercial scale manufacturing, ◦ Process improvement, ◦ Corrective and preventive action (CAPA), and ◦ Development data 12 www.drugragulations.org 4
  • 125. For manufacturing operations run under narrow operational ranges in fixed equipment, an expanded region of operation and an understanding of multi parameter interactions may not be achievable from existing manufacturing data alone.  Additional studies may provide the information to develop a design space.  Sufficient knowledge should be demonstrated, and the design space should be supported experimentally to investigate interactions and establish parameter/attribute ranges. 12 www.drugragulations.org 5
  • 126. There is no regulatory expectation to develop a design space for an existing product.  Development of design space for existing products is not necessary unless the applicant has a specific need and  Desires to use a design space as a means to achieve a higher degree of product and process understanding.  This may increase manufacturing flexibility and/or robustness. 12 www.drugragulations.org 6
  • 127. Design space can be applicable to formulations.  It may be possible to develop formulation (not component but rather composition) design space consisting of the ◦ ranges of excipient amount and ◦ its physicochemical properties (e.g., particle size distribution, substitution degree of polymer)  Based on an enhanced knowledge over a wider range of material attributes. 12 www.drugragulations.org 7
  • 128. The applicant should justify the rationale for establishing the design space with respect to quality attributes such as ◦ bioequivalence, ◦ stability, ◦ Manufacturing ◦ robustness etc.  Formulation adjustment within the design space depending on material attributes does not need a submission in a regulatory postapproval change. 12 www.drugragulations.org 8
  • 129. A set of proven acceptable ranges alone does not constitute a design space.  A combination of proven acceptable ranges (PARs) developed from univariate experimentation does not constitute a design space  Proven acceptable ranges from only univariate experimentation may lack an understanding of interactions between the process parameters and/or material attributes. 12 www.drugragulations.org 9
  • 130. However proven acceptable ranges continue to be acceptable from the regulatory perspective but are not considered a design space.  The applicant may elect to use proven acceptable ranges or design space for  different aspects of the manufacturing process 13 www.drugragulations.org 0
  • 131. Outer limits of the design space need not be evaluated during process validation studies at the commercial scale.  There is no need to run the qualification batches at the outer limits of the design space during process validation studies at commercial scale.  The design space should be sufficiently explored earlier during development studies. 13 www.drugragulations.org 1
  • 132. “If the experimental design is poorly chosen, so that the resultant data do not contain much information, not much can be extracted, no matter how thorough or sophisticated the analysis.  On the other hand, if the experimental design is wisely chosen, a great deal of information in readily extractable form is usually available, and no elaborate analysis may be necessary.  In fact, in many happy situations all the important conclusions are evident from visual examination of the data.” www.drugragulations.org 132
  • 133. Product Profile  Quality Target Product Profile (QTPP) CQA’s  Determine “potential” critical quality attributes (CQAs) Risk Assessments  Link raw material attributes and process parameters to CQAs and perform risk assessment Design Space  Develop a design space (optional and not required) Control Strategy  Design and implement a control strategy Continual  Manage product lifecycle, including continual Improvement improvement www.drugragulations.org 133