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WHO Training Workshop on Pharmaceutical Quality, GMP and Bioequivalence
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  1. János Pogány, pharmacist, PhD consultant to WHO Tanzania, 21 August 2006 E-mail: pogany.janos@chello.hu WHO Training Workshop on Pharmaceutical Quality, GMP and Bioequivalence Expression of Interest and Guidelines on Assessment of Applications for Prequalification Pogány - Tanzania

  2. Abbreviations APIActive Pharmaceutical Ingredient DRADrug Regulatory Authority EoIExpression of Interest FDCFixed-Dose Combination FPPFinished Pharmaceutical Product GMP Good Manufacturing Practices ICHInternational Conference on Harmonization MA Marketing Authorization PQPrequalification TRS Technical Report Series Yellow → emphasis Green → WHO Blue → ICH region Pogány - Tanzania

  3. Objectives of the workshop WHO Prequalification Program is motivated: • to involve countriesthat want to benefit from the (currently free-of-charge) PQ Program, and • to provide more information to African regulators about the ongoing activitiesand discuss how countries could cooperate in the area of dossier assessment and GMP inspection. Pogány - Tanzania

  4. Subjects for discussion • Interchangeability of multisource (generic) FPPs • EoI for Antimalarial Drugs • Global quality issues • Prequalification Experience–Illustrative deficiencies • Pharmaceutical Quality Information Form • Main points again Pogány - Tanzania

  5. Interchangeability (IC) Interchangeability (IC) of multisource FPPs = (Essential similarity with innovator FPP) = Pharmaceutical equivalence (PE) + Bioequivalence (BE) IC = PE+ BE Pogány - Tanzania

  6. CRITICAL VARIABLES OF FPP QUALITY INACTIVE INGREDIENTS ACTIVE INGREDIENTS PACKING MATERIALS Manufacturing authorization GMP standards FPP Manufacturing process Marketing authorization Pharmacopeiastandards NATIONAL DRA1 NATIONAL DRA2 Pogány - Tanzania

  7. Pharmaceutical equivalence • FPPs meet same orcomparablestandards (pharmacopoeia, marketing authorization) • Same API (chemical and physical equivalence) • Same dosage form and route of administration • Samestrength • Dissolution profile equivalence, when applicable • Comparable labeling • WHO-GMP(batch-to-batch uniformity of quality) • Stability equivalence Pogány - Tanzania

  8. High quality-risk APIs • FPP is not registered in the ICH region and associated countries • APIis not official inthe internationally used major pharmacopoeias and ICH guidelinesshould be used for evaluation • Reference standard/comparator is not available for: • Pharmaceutical equivalence studies • Bioequivalence studies • Require particular attention by NDRA as regards assessment of applications for marketing authorization Pogány - Tanzania

  9. Low quality-risk APIs • Certificate of suitability (CEP) is submitted (DRA) • Drug Master File • Open part (APPLICANT) • Closed part(DRA) • Pharmacopeia monograph is available • Literature evidence of stability • Synthesis impurities and degradantsare controlled by monograph • Class1 solvents excluded; class2 / class 3 solvents controlled • FPP is registered in the ICH region (DRA) Pogány - Tanzania

  10. EXPRESSION of INTEREST(4th edition,May 2005) Artemisinin-based Antimalarial FPPs

  11. EoI – Oral Preparations • Artesunate*+ Amodiaquine • Artemether*+Lumefantrine* • Artesunate*+ Mefloquine • Artesunate*+ SP (sulphadoxine / pyrimethamine) * Assessed originally by ICH guidelines*High quality-risk API + ... FDC or co-blistered (co-packaged) FPPs All oral FPPs include paediatric formulations. (EOI is included in the Notes Page of this and the subsequent slides) Pogány - Tanzania

  12. EoI – Other dosage forms • Artemether Injection and rectal FPPs • Artemotil (arteether) Injection • Artesunate Injection and rectal FPPs Only FPPs listed in the EOI are assessed. Pogány - Tanzania

  13. History and Current Status • First EOI published on 8 May 2002 • Assessment of dossiers started in July 2002 • FPPs[51 applications (2 cancelled) - five (three FPPs) approvalsas at 1 July 2006]. Antimalarial FPPs –manufactured inAfrica –have not yet been prequalified. • Problems delaying prequalification are discussed in forthcoming slides Pogány - Tanzania

  14. GLOBAL QUALITY ISSUES ANTIMALARIAL FPPs

  15. Global regulatory issues • If the product has been locally developed and manufactured, the national DRA mustevaluate the data set itself (p. 23)1. • If an evaluation report—critical summary and interpretation of the data, with conclusions—is not available it is not possible to seek a WHO-type certificate (p. 23)1. Pogány - Tanzania

  16. Global regulatory issues API or FPP originate „legally” from countries where: • Manufacture of APIsisnot regulated • Pharmaceutical exports and importsare not regulated • MA of FPPs is issued without evaluation or with a check-list assessment by the national NDRA Pogány - Tanzania

  17. Global regulatory issues • Formal stability studies are not required for MA • Biostudiesare not requiredfor MA • NationalGood Manufacturing Practices (GMP) do not comply with WHO-GMP requirements • API was not official in internationally used major pharmacopoeias (artemisinines and ARVs) Pogány - Tanzania

  18. Artemisin-derivative issues • No innovator FPP is registered in the ICH region. No comparator was available for: • Pharmaceutical equivalence studies • Bioequivalence studies • The APIs and FPPs were not official inthe internationally used major pharmacopoeias • WHO guides/SOPsapply to multisource FPPs. ICH guideshad to be used. Pogány - Tanzania

  19. PREQUALIFICATION EXPERIENCE ILLUSTRATIVE EXAMPLES OF DEFICIENCIES

  20. Chemical synthesis • Detailed information on the synthesis of non-compendial APIs—or a flow chart and textbook-level narrative on official APIs—was not provided. • The final purification, crystallizationand subsequent operations were not described in details. • Existence/absence of polymorphs, hydrates/solvates,solubility in water and organic solvents at 25oC, pKa, hygroscopicity datawere not submitted. Pogány - Tanzania

  21. Stability testing • Stress stability (forced degradation) testingwas limited to analytical method validation studies and were conducted under harsh conditions to produce degradants that may not be observed under the accelerated stress studies . • “Room temperature and accelerated stabilitytests are in progress.” Pogány - Tanzania

  22. Specifications of API • The melting point is 143-145oC (p.4) as opposed to 131-134oC± 1.5oC in the DMF. • Individual impurity limits were not based on batch analysis results and they were not in line with the ICH guidelines (e.g., NMT 1.0% instead of NMT 0.1%). • Residual solventswere included in the in-house monograph but not in the DMF. Pogány - Tanzania

  23. Specifications of API • Noadequate information was provided on the preparation and quality specification of primary (absolute) and secondary (working) standards. (For instance, lack of complete CoA, assay by two different validated methods, detailed information on storage, etc.). • HPLC method is described as an alternative assay to titration but acceptance limits are 97-103% as opposed to 98-102% in the DMF. Pogány - Tanzania

  24. Development pharmaceutics • A report was not submitted to identify and describe the formulation and process attributes that can influence batch reproducibility, product performance and FPP quality, including stability. • A tabulated summary of the compositions of the FPP used in clinical trials or stability studies and a presentation of dissolution profileswas not provided..Dissolution time was not studied at all. Pogány - Tanzania

  25. Stability of FPP and SmPC • Degradants, dissolution rate and profile, water content, hardness, microbiological attributes, etc. were not tested or quantified. • A national DRA-approved Summary of Product Characteristics (SmPC) type information for health professionals was not submitted. Pogány - Tanzania

  26. Correspondence with manufacturers • The stress data show that the blister pack does not protect the tablets even if overwrapped by additional protective packing.Supplier reduced expiry date. • Analysis of the tests for microbiological purity on„two (2) batches showed contamination with an invading yeast.” Pogány - Tanzania

  27. PREQUALIFICATION QUALITY REQUIREMENTS STANDARDS, GUIDELINES and TEMPLATES

  28. International Pharmacopoeia • Artemether • Artemisinin • Artemotil • Artenimol • Artesunate • Mefloquine Hydrochloride • Proguanil Hydrochloride BP Pogány - Tanzania

  29. International quality standards • Amodiaquine USP • Amodiaquine Hydrochloride USP • Lumefantrine • Pyrimethamine BP, PhEur, PhInt, USP • Sulphadoxine BP, PhEur, PhInt, USP Pogány - Tanzania

  30. Prequalification quality guidelines • Guide on Submission of Documentation for Prequalification of innovator Finished Pharmaceutical Products (FPPs) used in the treatment of HIV/AIDS, malaria and tuberculosis and approved by Drug Regulatory Authorities (DRAs) in the International Conference on Harmonization (ICH) region and associated countries, including among others the EU, Japan and USA Pogány - Tanzania

  31. Prequalification quality guidelines • Guideline on Submission of Documentation for Prequalification of Multi-source (Generic) Finished Pharmaceutical Products (FPPs) Used in the Treatment of HIV/AIDS, Malaria and Tuberculosis, together with eight (8) annexes. • Guidance on Variations to a Prequalified Dossier Pogány - Tanzania

  32. Prequalification quality guidelines • Supplement 1 [for use from July 2005 (CPH25)] - Dissolution testing • Supplement 2 – Revision 1[for use from May 2006 (CPH31)] - Extension of the WHO List of Stable (not easily degradable ARV) APIs1 1World Health Organization, WHO Technical Report Series, No. 863, 1996. Annex 5 Guidelines for stability testing of pharmaceutical products containing well-established drug substances in conventional dosage forms. Pogány - Tanzania

  33. Annex 8 to the Generic Guideline Pharmaceutical Quality Information FormThe PQIFcontainssummary information provided by the applicanton critical pharmaceutical quality attributes–chemistry, pharmaceutical formulation, manufacturing process and product performance– and their relevance to safety and efficacy, following the structure of the Generic Guideline and frequently in tabulated forms. Focus on analytical and stability issues, development pharmaceutics and specifications. Pogány - Tanzania

  34. Main points again • WHOprovidesinformation to African regulators and pharmaceutical manufacturers about the ongoing activities of the PQ program and discuss how countries could further benefit from cooperation in the area of dossier assessment and GMP inspection. • The EoI limits the number of FPPs. • Many DRAs did not assess generic FPPs –used in the treatment of HIV/AIDS, malaria and tuberculosis– and most manufacurers did not have dossiers for MA, at the beginning of PQ. Pogány - Tanzania

  35. Main points again • Artemisinin-derived APIs and FPPswere marketed at global level for decades without meetingbasic standards of quality. • It takes time to get into prequalification compliance • Develop new formulation • Data to be generated, tests carried out • GMP upgrade needed • Increase in the number of prequalified Artesunate Tablets is expected because there has been an official comparator since 2005. Pogány - Tanzania

  36. PLEASE MAKE USE OF THE OPPORTUNITYTO PARTICIPATE IN THE PREQUALIFICATION PROJECT Pogány - Tanzania