Topical Generic Development-Part II
Topical Generic Development-Part II
Regulatory Note
and globule size, and desired flux rate) and apply control the drug powder addition rate, rotor stator gap, rotor
strategies to mitigate risks. For example, the risk of speed and homogenization time are relatively critical
factors (i.e., CPPs) that may impact the homogeneity of
microbiological con tamination can be mitigated by micro
bial testing of the finished product and by monitoring the the drug product. Initial risk assessment for process
preservative content to ensure that the preservative level development is displayed in Table I showing the
potential for each unit operation to affect various CQAs.
is higher than the established minimum limit. This risk can
be further minimized by microbial testing of all raw Table IV gives an example of risk assessment for assay
materials and by an environmental monitoring program failure and lack of homogeneity using FMECA which is a
for the manufacturing and packaging areas. If generic more quantitative analysis of how each parameter would
firms put their efforts toward developing the afore afect these CQAs and ranks these upon the severity,
mentionced mitigation strategies for these risks and there probability, and detectability. In using this approach, it is
is no rend and no evidence of failure in these CQAS essential to quantitatively evaluate each risk thoroughly
there may be less need to implement a control strategy in lo identify the risk factors associated with the
batch release to monitor microbiological attributes in the manufacturing process.
finished drug product.
In another example, if a proposed manufacturing SCREENING DESIGN EXPERIMENT TO IDENTIFY
process calls for the emulsification of aqueous and oil CRITICAL FACTORS
phases to form a cream base and subsequent dispersion
of the drug substance into the cream base through Following the initial risk assessment, a screening design
powder eduction and a rotor-stator lype homogenizer, experiment, such as fractional factorial designs (i.e..
Chang el a
Table I1. Raw Matcrial Risk Assessment and Action Plans
Formulation Potential impact on
component Potential risk drug product CQAs Action plan
Drug substance Particle size Shift in content uniformity, Micronized drug substance with identical solid state
or morphology change drug release and dermal form to the RLD from aqualified source is used
distribution of the drug for the drug product manufacturing and particle
size is measured as part of drug substance release
testing with a tight limit of D90 of not more
than 10 um
Drug concentration in the cream preparation
needs to be monitored to ensure homogeneity
White petrolatum Viscosity variation
of drug distribution in the drug product matrix
Shift in viscosity White petrolatum from a qualified source is used for
the drug product manufacturing. Consistency is
measured as part of every white petrolatum lot
via release testing using more stringent limits than
USP limits (consistency value 100to 200 vs. USP
limits 100 to 300) to ensure product viscosity closely
Propvlene Glvcol matching that of the RLD.
Unidentifed
stearyl alcohol Variation in stearyl Shift in iscosity Each lot of stearyl alcohol should contain not less
alcohol content than 90.0% of stearyl alcohol. Monitor and trend
Polysorbate 60 viscosity of the product.
Methyl and
Unidentified
Possible chemical instability Shift in preservative The antimicrobial properties of the drug product
propyl Paraben of preservatives in the cream content in the cream are studied during the product development
stage through antimicrobial effectiveness test.
Based on the results from these microbial
studies, set an adequate lower limit of preservative
content for drug product release and stability
specifications to reduce the risk of microbial
Purified water Increased water activity contamination.
Drug product microbial limit Quality system, cGMP
and bacteria growth potential
Manufacturing operation
Drug product CQA Pharmacy Aqueous phase Oil phase Emulsification Drug powder eduction phase
Appearance Low Low Low Medium Medium
Assay High Low Low Low Low
Impurities Low Low Low Low Low
Content uniformity Low Low Low Low High
Drug particle size Low Low Low Low High
High
Viscosity Low Low Low Medium
Note for relative risk ranking system: Low broadly acceptable risk: no further investigation is needed. Medium risk is accepted: further
investigation may be needed in order to reduce the risk. High risk is unaceptable: further investigation is needed to reduce the risk
+ 4 + 4
4 4.5
5.1
2
4.2
3 +
4.8
4
5.9
5
1.2
6.9
6.2
8 2.5
3.8
10 6.2
+
11 7.2
+
12 28.2 27.7 30.5
33.1 22.3 30.1 22.6
Sum + 58.5 29.0 28.0 27.1 34.7
36.2 28.4 35.9 30.3 30.8 28.0
0 29.5 30.5 31.4 23.8 25.4
Sum 58.5 58.5 58.5 58.5
58.5 58.5 58.5 58.5
Check Sum 58.5 58.5 58.5 58.5 -0.7 -2.1 3.1 2.5
10.9 7.7 -13.9 1.70
Difference 58.5 -0.5 -2.5 -4.3 0.42
-2.32" 0.28 -0.12 0.35 0.52
Effect 4.99 -0.08 -0.42 -0.71 1.82º 1.28
-0.65 -1.05 -3.03 -0.41 -0.51
-1.50 1.25 1.28 -3.01
Lower CL -1.01 -1.34 0.81 1.28 1.45 1.35
2.45 2.48 -1.81 1.21
0.85 0.51 0.22
Upper CL
aStatistically significant factor effect =0.36-4.
+ UFE +UFE; +UFE) /q)=(0.28) +(-0.12)' +(0.35)° +(0.52)° +(0.42)°/s
Standard error of a factor effect, SpE = (UFE; + UFE; unassigned
where UFE is unassigned factor effect and q is number of factors
I value for 95% confidence and 5 degree of freedom=2.57 CL=factor effect -0.93 and upper CL=factor effect +0.93
Plus or minus part of CL (95%)=0.364 x 2.57=0.93: lower
1900
1800
1200
170 125
1606
150
1400
1300
1200
1200
1100
110
15
1000
eton Tme
RS75 43
Homogenlon Tme 05
Parameter Estimates Powder Educson Rate
Tom
Intercept Estimate Std Error t Ratio
Prob>|tl
Homogenization Time(10,30) 1.6943662 0.24363 O.0002
Powder Eduction Rate -1.44
0.180048 -8.00 <.0001
Rotor Speed(1000,2o0o) 0.98 0.180048 5.44 0.o010
Homogenization TimePowder Eduction Rate -0.49 0.180048 -2.72 0.0297"
Homogenization TimeRotor Speed 0.225 0.2013 1.12 0.3006
Powder Eduction Rate"Rotor Speed -0.475 0.2013 -2.36 0.0504
Homogenizat1ion Tim 0. 0.2013 0.50
Homogenization Time
Powder Eduction RatePowder 2.5098592 0.347842
O.6346
Table VII. Application of Control Strategy to Mitigate ldentified Risks in Process Parameters
Manufacturing operation
Drug
product
Aqueous phase: Oilphase: Emusification
RT mixing and heating to 75°C phase: emulsification
CQA
Pharmacy heating to 75°C Drug powder eduction
and mixing and cool down
phase
Appearance Low Low Low Low Low
Assay Controlled by cGMP Low Low Low Low
training of dispensing
personnel and
manufacturing
workers
Impurities Low Low Low Low Low
Content Uniformity Low Low Low Low Controlled by eduction
rate, rotor speed and
Drug Particle Size Low Low homogenization time
Low Low Low
Viscosity Low Low Low Low Low
Note that temperature for mixing aqueous and non-aqueous phases is
based on the
ingredients are in solution or molten state (ie., in the current case, temperature range is melting points for the raw malerials to ensure all the
targeted at 75C). The cream base is cooled to 25°C to
30°C, before dispersion of the drug substance to the cream base
Based on experience and knowledge obtained during process development, risk rating was changed to low risk
° Response surface optimization was used to provide guidance for the manufacturing parameters to mitigate risk
Chang et a
Contour Profiler
Contour Profiler Current X
Contour Profiler
HorizVert Factor
CurrentX OO Homogenzaton Time 20
HorizVertFactor
HorizVert Factor Curret X O O Homogenzation Time 20
O O Powder Educion Rate
1500
OHomogenzation Time OPowder Educton Rate O Rotor Speed
Powder Eduction Rate 1500 Currert Y Lo Limit HI Umt
ORotor Speed Cortour
1500 HLimit Response 1 6943662
O Rotor Speed Contour Current Y Lo Limit
Lo Limt Hi Limit Response 5RSD
Response Contour Current Y
sRSD
4 16943662
2000 SRSO
LRSD
2000 RSO
SRSD
1900
1900
1800
1800
1700-1.325
1700
1600
1600
1600
1500
1400
1400
1300
1300
05 1200
1200
1100
1100
1000-7s
1000
1 1
10 15 20 15 20
Homogenizaton Trme Powder Educbon Rate
Homogenization Time
Parameter Estimates
Estimate Std Error t Ratio Prob>it|
Term
1.6943662 0.24363 6.95 O.0002*
intercept -8.00 <.0001
Homogenization Time(10,30) -1.44 0.180048
0.98 0.180048 5.44 0.0010*
Powder Eduction Rate
-0.49 0.180048 -2.72 0.0297*
Rotor Speed(1000,2000)
Homogenization TimePowder Eduction Rate 0.225 0.2013 1.12 O.3006
-0.475 0.2013 -2.36 O.0504
Homogenization TimeRotor Speed
Powder Eduction RateRotor Speed 0.1 0.2013 0.50 O.6346
Homogenization Time"Homogenization Time 2.5098592 0.347842 7.22 O.0002*
process sensitivities developed in the R&D stage form the not batch size related), confirmation run(s) is/are needed
foundation for scale-up and production batch manufactur to verify the validity of the design space at commercial
ing process development. If projected process parameters scale. On the other hand, if projected process parameters
are within the design space obtained in the R&D stage are far off from the design space generated from R&D
(ie., for situations as the scale-up façtor is very low with batches, experimentation to scrutinize the process param
Part lI: Quality by Design for Topical Semisolid Products
rble VI. Factorial Design to Investigate the Effct of Acid Value Variation for Celyl Ester Wax and Glyceryl Monostearate Used in a
Cream Formulation on Chemical Stability of a Drug
Design Observations"
The percent level of Impurity A detected for stability samples stored at 40°CI75% RH for six months
bCodedX, (acid value of cetyl ester wax used in the experiment )
Coded X, (acid value of glyceryl monostearate used in the cxperiment)
value of glyceryl monostearate-3.5)/2.5
Coded AX;-(acid value of cevl ester wax -3)/2 and coded X,=(acid
Intercept=(0.135 + 0.965 + 1.92 + 2.59)/4 = 1.4025
Estimate of main effect of factor X;= J(0.965- 0.135) + (2.59--0.965)1/2-- 1.92))/2=0.75
= 1.71
Estimate of main effect of factor X, |(1.92 - 0.135) + (2.590.135)l/2 = -0.08
Estimate of interaction effect=((2.59-- 1.92) -- (0.965 -- noalc.a/r)xto025, where degree
confidence interval for an effect, based on r replications of a2² factorial design, is estimate effect +(S
A 95% 1/2
of freedom=4(r-1) for lo025 for df-4, we find that o.02s=2.776. Then, (Soled/r)
consulting the t table
The number of replicates is r=2 and effect=0.75+0.086, X, efect=1.71+0.086, and interaction =0.08+0.086. It can be cóncluded that
(0.001925/2 )* x 2.776 =0.086, so that X, is not statistically significant. The prediction
factor effects (i.e., acid value for two excipients) seem to be real and the interaction term
both X,
equation is Y = 1.4025 + 0.375 X; + 0.8525 X, - 0.04 X;
risk management to
size to obtain the from OTPP to COAs, and rom
scale-up and commercial product batch aim to boost productivity and
regulatory flexibility. DoE. These new endeavors understanding of the
product quality in the end. The
compa
CONCLUSION
myriad roles that QbD plays has pharmaceutical
development and
nies looking at drug product
could not a
emphasis is manufacturing issues in a way they simply risk-based
Across the pharmaceutical industry, the few decades ago. This systematic science and
knowledge from raw materials
on QbD and enhanced approach will lead to the development of control
strate
CPPs),
(e.g.. CMAs) to manufacturing prOcesses (e.g.,
Contour Profiler
Current X
HorizVert Factor
O O acid value of cetyl ester
wax
6
acid value of glyceryl monostearate Hi Limit
Contour Current Y Lo Limit
Response 1
2.8 2.59
%impurity A
%impurity A
6
5.5
1.65
monostearat
5
8 4.5 14
glycery4
1.15
of
value
acid
S 2.5
2
1.5
1 4 5
3.5 4
1 1.5 2 2.5 3
acid value of cetyl ester wax