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By Emil Ciurczak, Contributing Editor
Although this conference was not specifically designed to focus on Process Analytical Technology (PAT) or Quality by Design (QbD), it was the first I have attended where almost every speaker referred to QbD. Of course, drug products are complex organic delivery systems for the API and much of the QbD emphasis is placed on producing fresh batches. It was refreshing to hear that speakers considered the length of time a drug maintained its “deliverability” to be an essential element of its design.
|Click here to hear Emil Ciurczak's interview with workshop organizer Saji Thomas (aka associate director for QC operations at Par Pharmaceuticals, Spring Valley, N.Y.). They discuss the industry trends and conditions that necessitated such a workshop, and how Thomas secured buy-in from industry groups including AAPS, EAS, PhRMA, GPhA and CHPA.|
Gary Buehler (Director, Office of Generic Drugs, FDA/CDER) made the expected disclaimer that his opinions did not represent Agency policy, as did all the FDA speakers. The interesting fact covered in his talk was the large number of product recalls based on stability failures. Buehler stressed that QbD should be used to produce a product that delivers the API properly not only when first produced, but for the duration of the life cycle of that lot.
Outside the U.S. — Several speakers emphasized that the U.S. is only part (albeit a large part) of the pharmaceuticals-consuming world. When determining conditions for stability testing, “real world” conditions should be taken into account. These include what happens after a bottle of product is opened as well as when stored under less-than-optimal conditions. Indeed, “optimal conditions” may not exist at all in developing countries. Saranjit Singh (NIPER, S.A.S. Nager, Punjab, India) pointed out that India has climates ranging from alpine tundra and glaciers in the north to desert in the west to tropical regions in the southwest. Packaging and stability tests should take all these climatic variations into consideration.
Central America and the Caribbean was the region discussed by Anabelle Castro (Roche Servicios, Heredia, Costa Rica). She outlined the applicable requirements: ICH Q1A (R2) and Q1F, EMEA CPMP/QWP/122/02 (rev 1), ICH Q5C, Executive decree #504 (Panama), Decree #33850 (Costa Rica), RTCA11.01.04:05 (GT, HD, NIC & ES), WHO Working document (QAS/06.179.Rev.1) and others for the selection of batches, etc. Castro covered the large number of guidances and requirements that exist in the region and addressed how they can all be met while still making a profit.
The particulars of stability requirements in the Arab countries were discussed by Abdel Aziz Seleh (WHO, EMRO, Alexandria, Egypt). Seleh shared a number of presentations by researchers from throughout his area. Climatic regions were assigned and accordingly, long-term storage conditions were recommended. Conditions varied somewhat from 25°C to 30°C and from 35% to 65% relative humidity. These variations reflect that the region contains arid mountains and deserts as well as more humid and cooler zones. Thus, the storage will more realistically mirror outside conditions.
In a similar approach, Lucky S. Slamet (NADFC, Indonesia) spoke about the ASRAN zone IV and ASEAN guidelines on stability studies. The major difference from the other papers was that for studies in this region, the upper limit for humidity would be 75% in order to mirror local conditions.
In transit — Outside the normal purview of stability testing would be the time a product spends in-transit/storage at third-party warehouses. Timothy Schofield (Merck & Co., West Point, Pa.) addressed the issue of excursions during transport. Using ICH guidance, Schofield explained several models for predicting shelf life after a temperature excursion. Different regions use different models and methods for prediction. Indeed, he noted that finding the “trigger” for what constitutes an excursion also varies from one location to another.
Schofield described some complex release models and used risk analysis to attempt to recalculate expiry dates. After going over the assumptions and known or assumed storage conditions, he demonstrated some means of recalculation (for example, the Principle of Similar Triangles).
Split tablets and repackaging — Given that I administer split tablets to my dog, this topic caught my attention. Due to HMO costs, a number of physicians prescribe a stronger dose of medicine, instructing the patient to split the tablets, thus saving on prescription costs. Repackaging from larger bottles to smaller containers or even blister packs by distributors may not give the same lifetimes as when products are tested in-house in the original containers.
Vilayat Sayeed (FDA/CDER’s Office of Pharmaceutical Science) gave real world examples of the stability profiles of split tablets. Using Gabapentin and an OTC product with four actives as examples, he showed potency and dissolution results from the studies. As well, he performed thermal analysis tests. His conclusions were that type G1 and G2 tablets were unaffected, while G3 tablets showed a decline in properties. These results were based on sample weight, hardness, potency, moisture, dissolution, and TGA and DSC experiments.
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