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DRUG QUALITY SYSTEM FOR THE 21 ST CENTURY PQRI/FDA April 22-24. CHANGES WITHOUT PRIOR APPROVAL AN FDA PERSPECTIVE Dennis M. Bensley, Jr., Ph.D. Center for Veterinary Medicine, FDA. OUTLINE. INTRODUCTION BACKGROUND CURRENT FDA ASSESSMENT CURRENT RISK ANALYSIS COMPARABILITY PROTOCOL

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DRUG QUALITY SYSTEM FOR THE 21ST CENTURYPQRI/FDA April 22-24

CHANGES WITHOUT PRIOR APPROVAL

AN FDA PERSPECTIVE

Dennis M. Bensley, Jr., Ph.D.

Center for Veterinary Medicine, FDA


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OUTLINE

  • INTRODUCTION

  • BACKGROUND

  • CURRENT FDA ASSESSMENT

  • CURRENT RISK ANALYSIS

  • COMPARABILITY PROTOCOL

  • STRATEGIC GOALS

  • CONCLUSION


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INTRODUCTION

  • Changes Without Prior Review working group established by FDA’s Drug GMP Steering Committee

  • Working Group members:

    -Ajaz Hussain, Co-chair (CDER)

    -Nancy Sager, Co-chair (CDER)

    -Kathy Jordan, Project Manager (CDER)

    -Nick Buhay (CDER)

    -Chris Joneckis (CBER)

    -John Finkbohner (CBER)

    -Dennis Bensley (CVM)

    -Nancy Rolli (ORA)

    -Patricia Alcock (ORA)

    -Marybet Lopez (ORA)

    -Janet Showalter (OC, OIP)

    -Lynn Whipkey (OC, OCC)


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INTRODUCTION

  • Charge of Working Group:

    -examine current state of the supplemental change approval process, specifically those manufacturing changes requiring prior FDA approval.


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INTRODUCTION

  • Charge of Working Group:

    -examine current state of the supplemental change approval process, specifically those manufacturing changes requiring prior FDA approval.

    -identify and recommend implementation of other means to reduce reporting requirements, for example the use of risk management tools, comparability protocols, product development information, and process control improvements (e.g., PAT).


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INTRODUCTION

  • Purpose of Workshop

    -Present a summary of FDA’s current thinking and activities regarding the supplemental change approval process.


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INTRODUCTION

  • Purpose of Workshop

    -Present a summary of FDA’s current thinking and activities regarding the supplemental change approval process.

    -Stimulate discussion and constructive feedback from stakeholders regarding the current and desired future state of the change approval process.


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BACKGROUND

  • Legal Requirements

    - The applicant must notify FDA of each manufacturing change in accordance with section 506A of the Federal Food, Drug, and Cosmetic Act and, when finalized 21 CFR 314.70 (CDER) and 514.8(CVM).


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BACKGROUND

  • Legal Requirements

    - The applicant must notify FDA of each manufacturing change in accordance with section 506A of the Federal Food, Drug, and Cosmetic Act and, when finalized 21 CFR 314.70 (CDER) and 514.8(CVM).

  • An applicant must inform the FDA about each change in the product, production process, quality controls, equipment, facilities, responsible personnel, or labeling established in the approved license application(s) (CBER 601.12).


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BACKGROUND

  • Legal Requirements

  • The applicant must assess the effects of any change on the identity, strength, quality, purity, and potency of the drug as they may relate to the safety and effectiveness of the drug before distributing product made with the change (Section 506A of Act, Section 116 FDAMA).

  • Four legal reporting categories under FDAMA: prior-approval, CBE (immediate), CBE-30 and annual report.


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BACKGROUND

  • Filing Categories:

    -Prior-approval (major change): Substantial potential to adversely affect the identity, strength, quality, purity, or potency of a product as they may relate to the safety or effectiveness of the product. Product made with change may not be distributed until approval.


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BACKGROUND

  • Filing Categories:

    -Prior-approval (major change): Substantial potential to adversely affect the identity, strength, quality, purity, or potency of a product as they may relate to the safety or effectiveness of the product. Product made with change may not be distributed until approval.

    -CBE or CBE-30 (moderate change): Moderate potential….Product distribution upon receipt of application to FDA (CBE) or 30 days after receipt of application to FDA, if acceptable (CBE-30).


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BACKGROUND

  • Filing Categories:

    -Prior-approval (major change): Substantial potential to adversely affect the identity, strength, quality, purity, or potency of a product as they may relate to the safety or effectiveness of the product. Product made with change may not be distributed until approval.

    -CBE or CBE-30 (moderate change): Moderate potential….Product distribution upon receipt of application to FDA (CBE) or 30 days after receipt of application to FDA, if acceptable (CBE-30).

    -Annual Report (minor change): Minimal potential….Annual reportable and immediate product distribution.


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CURRENT FDA ASSESSMENT

  • Did Section 116 of FDAMA (506A of the Act) meet the expectation of:

    -providing regulatory relief by lessening the reporting requirements of manufacturing changes without compromising the drug’s “quality”, safety or effectiveness?


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CURRENT FDA ASSESSMENT

  • The reporting of many manufacturing changes has been provided through regulations and guidances:

    -Section 506A of FFD&C Act (CDER, CBER and CVM)

    -Regulations (being revised 314.70, 514.8, 601.12).

    -”Changes” Guidances:

    Changes to an Approved NDA or ANDA (CDER)

    Changes to an Approved Application: Biological Products (CBER)

    Changes to an Approved Application for Specified Biotechnology and Specified Synthetic Biological Products (CDER/CBER)

    Changes to an Approved NADA or ANADA (CVM)

    -Various PAC and SUPAC Guidances


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CURRENT FDA ASSESSMENTImpact of FDAMA on Filing

CVM

  • A significant number of CMC changes are currently being reported in CBE supplements or in annual reports.


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CURRENT FDA ASSESSMENTImpact of FDAMA on Filing

CDER Data (%Prior Approval/CBE Supplements)

FY99FY00FY01

  • NDAs

  • Prior Approval62%48%39%

  • CBE38%52%61%

  • ANDAs

  • Prior Approval82%26%34%

  • CBE18%74%66%


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REPORTINGCBER CMC CHANGES

IMPACT OF FDAMA/ GUIDANCE

NON-PDUFA PRODUCTS

PDUFA PRODUCTS


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CURRENT FDA ASSESSMENT

  • FDAMA has significantly reduced the reporting requirements for manufacturing changes, however FDA recognizes that there could be additional improvements in the change reporting process.


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CURRENT FDA ASSESSMENT

  • Concerns with current regulatory supplemental change process:

    -Though the relative percentage of prior-approval supplements as compared to other reporting categories have significantly decreased, the number of prior-approval supplements are starting to increase.


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CURRENT FDA ASSESSMENT

  • Concerns with current regulatory supplemental change process:

    -Though significantly reduced overall from “pre-FDAMA” times, the number of reported prior approval changes remain high for certain product types/processes (e.g., sterile products).


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CURRENT FDA ASSESSMENT

  • Concerns with current regulatory supplemental change process:

    -Recognize that any prior approval change could impact business planning and possibly impede innovation.


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CURRENT FDA ASSESSMENT

  • Concerns with current regulatory supplemental change process:

    -No guarantee that the prior approval supplement will be approved during “first round.” CVM’s experience is that approximately 40% of “first round” prior approval supplements are found to be incomplete (data from 2000-2003).


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CURRENT FDA ASSESSMENT

  • Concerns with current regulatory supplemental change process:

    -Regulatory compliance dilemma in finding unacceptable, i.e., inadequately assessed or documented, CMC changes in CBE or annual reports.


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CURRENT FDA ASSESSMENT

  • Potential solutions identified by FDA to lessen reporting requirements:

  • Use of comparability protocols;


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CURRENT FDA ASSESSMENT

  • Potential solutions identified by FDA to lessen reporting requirements:

  • Use of comparability protocols;

  • Drafting and publishing more PAC/SUPAC guidance documents;


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CURRENT FDA ASSESSMENT

  • Potential solutions identified by FDA to lessen reporting requirements:

  • Use of comparability protocols;

  • Drafting and publishing more PAC/SUPAC guidance documents;

  • Identifying potential risk management tools;


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CURRENT FDA ASSESSMENT

  • Potential solutions identified by FDA to lessen reporting requirements:

  • Use of comparability protocols;

  • Drafting and publishing more PAC/SUPAC guidance documents;

  • Identifying potential risk management tools;

  • Encouraging the use of product development information and process controlimprovements (e.g., Process Analytical Technologies).


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CURRENT RISK ANALYSIS

Potential for CMC

Change To Adversely

Affect Drug

Prior Approval

Supplement?

Levels of Risk

HIGH

YES

SIGNIFICANT

SOME

NO*

MODERATE

*CBE Supplements Required

LOW

NO

MINIMAL


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CURRENT RISK ANALYSIS

  • FDA’s determination of a CMC change as major or requiring prior approval:

    -What is the likely impact of the change on the identity, strength, quality, purity and/or potency of the drug product? If FDA believes there is a potential adverse affect, then major change.


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CURRENT RISK ANALYSIS

  • FDA’s determination of a CMC change as major or requiring prior approval:

    -Will additional clinical or other “non-CMC” (e.g., toxicological) studies be required? If yes, then likely major change.


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CURRENT RISK ANALYSIS

  • FDA’s determination of a CMC change as major or requiring prior approval:

    -Is the reported change either not well described, too complex or is the potential impact on the drug’s safety or effectiveness not certain? If yes, then likely major change.


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CURRENT RISK ANALYSIS

  • FDA’s determination of a CMC change as major or requiring prior approval:

    -If applicable, what is the current GMP status? If unacceptable, then likely major change.


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CURRENT RISK ANALYSIS

  • The question to address when a risk assessment is performed regarding a CMC change:

    What is the potential (risk) for the change to adversely affect the identity, strength, quality, purity, or potency of a product as they may relate to the safety or effectiveness of the product?


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CURRENT RISK ANALYSIS

  • The potential risk for a CMC change increases when the knowledge regarding the potential impact of the change decreases.


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CURRENT RISK ANALYSIS

  • The potential risk for a CMC change increases when the knowledge regarding the potential impact of the change decreases.

  • What is the purpose of prior approval supplements for specified CMC changes?


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CURRENT RISK ANALYSIS

  • The potential risk for a CMC change increases when the knowledge regarding the potential impact of the change decreases.

  • What is the purpose of prior approval supplements for specified CMC changes?

    -Identified major changes are those changes that have a substantial potential to adversely affect the drug.


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CURRENT RISK ANALYSIS

  • The potential risk for a CMC change increases when the knowledge regarding the potential impact of the change decreases.

  • What is the purpose of prior approval supplements for specified CMC changes?

    -Identified major changes are those changes that have a substantial potential to adversely affect the drug.

    -Allows FDA time to review and concur (or not concur) with the proposed major change and its assessment prior to product distribution.


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CURRENT RISK ANALYSIS

  • FDA tends to be conservative in regard to accepting levels of risk, i.e., if we are not certain about the potential risk, then a higher filing category will likely be required.


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CURRENT RISK ANALYSIS

  • FDA employees use risk analysis daily, for example:

    -Deciding whether a change is major or moderate (30-day CBE assessment)

    -Deciding whether the assessment of the change is satisfactory or not (review process)

    -Deciding whether a cGMP inspection is required (e.g., CBER’s SOPP 8410: Determining When Prelicense/Preapproval Inspections Are Necessary)


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CURRENT RISK ANALYSIS

  • FDA employees use risk analysis daily, for example:

    -Deciding whether a change is major or moderate (30-day CBE assessment)

    -Deciding whether the assessment of the change is satisfactory or not (review process)

    -Deciding whether a cGMP inspection is required (e.g., CBER’s SOPP 8410: Determining When Prelicense/Preapproval Inspections Are Necessary)

  • However, risk assessments for CMC changes are neither formalized nor uniformly structured throughout FDA.


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CURRENT RISK ANALYSIS

  • Possible ways to reduce the risk potential include the use of:

    1. Comparability protocols

    Premise: FDA’s acceptance of proposed assessment of anticipated change will likely lessen risk for implementing the change and should lead to less burdensome reporting category


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CURRENT RISK ANALYSIS

  • Possible ways to reduce the risk potential include the use of:

    2. An applicant may establish their own filing criteria based on developmental information in original or supplemental applications (“Make your own SUPAC”).

    Premise:Increase in scientific understanding/knowledge of change’s impact may lessen risk for implementing change and could lead to less burdensome reporting category


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CURRENT RISK ANALYSIS

  • Possible ways to reduce the risk potential include the use of:

    3.incorporating significant process control improvements (e.g., PAT).

    Premise: Improvement in process controls, may lessen risk for producing poor product and could lead to less burdensome reporting category


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CURRENT RISK ANALYSIS

  • Can other risk analysis models be used to identify the level of risk for implementing CMC changes?

  • For example, can we identify, through risk assessment, low-risk drugs, dosage forms, processes, etc. and significantly reduce the number of changes requiring prior approval before implementation?


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COMPARABILITY PROTOCOL

  • What is a CP?

    A well-defined, detailed written plan that prospectively specifies the tests and studies that will be performed, analytical procedures that will be used, and acceptance criteria that will be achieved to assess the effect of specific CMC changes for specific products.


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COMPARABILITY PROTOCOL

  • Draft Guidance for “small molecules” recently published (public comment by 6/25/03).

  • CP described in regulations (current and/or proposed 314.70, 514.8 and 601.12).

  • FDA believes that additional prior approval changes can be reported in CBEs or annual reports through the use of a CP.


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COMPARABILITY PROTOCOL

  • Uses and benefits of CP:

    -Can allow for a reduced reporting category of CMC changes covered by the approved CP.

    -CP can describe single or multiple-related CMC changes including those that may occur sequentially over a period of time.


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COMPARABILITY PROTOCOL

  • Uses and benefits of CP (cont.):

    -Earlier implementation of manufacturing changes.

    -Likely reduction in incomplete/deficiency letters issued by FDA (more “first-round” approvals), because the means of assessing the change has been approved in the CP.


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COMPARABILITY PROTOCOL

  • Uses and benefits of CP (cont.):

    -Allows sponsors to design own “changes” filing and documentation criteria based on experiences with the drug product or similar drug product, e.g. developmental studies. “Make your own SUPAC” concept.


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COMPARABILITY PROTOCOL

  • Uses and benefits of CP (cont.):

    -Allows sponsors to continually improve manufacturing processes without necessarily requiring prior FDA approval (potential for PAT implementation).

    -Reduces the potential risk for the change to adversely affect the drug.

    -A potential win-win situation for public, industry, and FDA.


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COMPARABILITY PROTOCOL

  • Limited CDER experience and no CVM experience.

  • CBER experience:

    -More than 100 comparability protocols have been successfully used for CMC changes for all product classes since 1997.

    -Submission of developmental information in CPs has convinced CBER to accept reduced reporting categories for some CMC changes.


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Strategic Goals

  • Publish Draft Comparability Protocol for “Large Molecules”


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Strategic Goals

  • Publish Draft Comparability Protocol for “Large Molecules”

  • Finalize both CP Guidances.


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Strategic Goals

  • Publish Draft Comparability Protocol for “Large Molecules”

  • Finalize both CP Guidances.

  • Continue to amend or introduce new PAC/SUPAC guidances.


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Strategic Goals

  • Publish Draft Comparability Protocol for “Large Molecules”

  • Finalize both CP Guidances.

  • Continue to amend or introduce new PAC/SUPAC guidances.

  • Publish final “changes” regulations 314.70, 514.8 and 601.12.


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Strategic Goals

  • Conduct study to evaluate existing data on prior approval changes and identify opportunities for further reducing of reporting categories:

    -Determination of the number and types of prior approval supplements submitted to each Center over a designated time period.


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Strategic Goals

  • Conduct study to evaluate existing data on prior approval changes and identify opportunities for further reducing of reporting categories:

    -Determination of the number and types of prior approval supplements submitted to each Center over a designated time period.

    -Identify other potential risk models or other means for reducing reporting categories.


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Strategic Goals

  • Conduct study to evaluate existing data on prior approval changes and identify opportunities for further reducing of reporting categories:

    -Determination of the number and types of prior approval supplements submitted to each Center over a designated time period.

    -Identify other potential risk models or other means for reducing reporting categories.

    -Consider additional ideas as result of discussion and feedback received during this workshop.


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CONCLUSIONS

  • The following are the discussion points for consideration during the individual breakout sessions:

  • Scientific risk-based approaches for identifying low risk manufacturing changes that can be implemented without prior FDA approval


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CONCLUSIONS

  • The following are the discussion points for consideration during the individual breakout sessions:

  • Draft guidance on comparability protocols for small molecules and development of a comparability protocol guidance for proteins


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CONCLUSIONS

  • The following are the discussion points for consideration during the individual breakout sessions:

  • Effective use of development data and other information to justify less burdensome filing requirements for post-approval manufacturing changes


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CONCLUSIONS

  • This is your opportunity to comment on and provide your ideas on the current supplemental approval process and your view of the ideal future state!


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