Transcript Impact of Stability on Setting and Meeting

Impact of Stability on Setting
and Meeting Specifications
in an Uncertain World
William R. Porter
MSBW 2012
Setting and Meeting Specifications
Statistical approaches to setting
specifications and devising methods to
meet them have been developed in many
different contexts, including:
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
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
Widget manufacturing,
Biologicals manufacturing,
Classical stability trial design and
Measurement uncertainty.
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Widget Manufacturing
Classical industrial quality control was developed
for the durable goods industries, especially for
manufacture of machined items.
 Parts had to mate together without customization.
 Primary source of product variability was the
manufacturing process itself.
 Measurement tools were highly precise and
accurate…
• …as shown by Gage R&R (repeatability & reproducibility)
studies
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Biologics Manufacturing
The three most important things required for
developing a biologics product have been:
 Analytical methods, analytical methods and analytical
methods.
• (i.e., location, location and location—just as in real estate
investment—but scale [dispersion] is even more important.)
• The major source of variability in product performance was
traceable to the methods used to monitor quality, particularly
bioassays.
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Classical Stability Trial Design
Stability trial design was formalized in ICH
guidelines Q1A, Q1B, Q1C, Q1D and especially
Q1E.
 ICH Q1E Appendix B suggests designs and methods
for data analysis and interpretation.
• Focus is on studies with only a few batches using ANCOVA.
• Methods to evaluate batch variation are unconvincing and
established by fiat.
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Measurement Uncertainty
All measurements are uncertain; there are none, which
are not uncertain.
 All measurements are wrong, but some are useful.
• (with apologies to G. E. P. Box)
 Only a quantitative estimate of uncertainty distinguishes useful
data from worthless garbage.
• In Bayesian terms, numbers without informative prior distributions are
worthless. Useful measurements have informative priors.
 Beginning in the 1990’s, mainly in Europe, efforts to formalize
evaluation of measurement uncertainty were undertaken.
• GUM: Guide to the expression of uncertainty of measurement (1995, 2008).
• EURACHEM/CITAC Guide: Use of uncertainty information in compliance
assessment (2007).
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Measurement Uncertainty (2)
The pharmaceutical industry has been slow to incorporate
accepted international practices for quality control of
chemical measurements.
 Producers must set tighter specifications than required by
customers to allow for measurement uncertainty.
Formal uncertainty studies as part of method validation
need improvement.
 This should not be a problem, as methods for assessing
measurement uncertainty are now well-established—we just
have to get on with it.
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Specification Uncertainty
Many specifications are digital—that is, expressed as
decimal numbers with a specified number of significant
digits.
 Digital specifications also imply the expected maximum
uncertainty in measurements used to confirm compliance to
specifications.
 Frequently, the number of significant digits in written
specifications are TOO SMALL to meet actual quality
expectations.
• ICH impurity guidelines are at least one order of magnitude too
imprecise.
• Round off errors result.
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Customer Expectations
We know what patients expect.
 What P(failure) is acceptable?
Regulators expect that any sample, selected for
the convenience of the regulators from normal
supply channels, will meet specifications for
purity and potency at all times within the stated
shelf life of the drug product for all batches.
 The testing can be performed by any qualified
laboratory using any qualified equipment and
reagents by any trained personnel following validated
SOP’s.
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Sampling
What distinguishes the approaches
used for widgets, biologics and
classical stability trials is how they:
 Address the extent to which
measurement uncertainty contributes
to overall variation, and.
 Address within-batch and betweenbatch sampling as sources of
McConnell J, Nunnally BK,
variation.
McGarvey B. Sampling—The
• Sampling has been described as
“The Mother Lode” of all errors.
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‘Mother Lode of All Errors. J.
Validation Technol. 18(1); 45-49
(2012).
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Convenience Sampling
Since any sample from any batch (not just
‘random’ samples) must meet specifications
during the entire shelf life, we need to know:
 What is the variability of samples selected within
batches?
 What is the variability of samples selected between
batches?
 How confident are we of our estimates for these
components of variance?
 How does measurement uncertainty affect our
estimates?
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Batch Variation in Widgets
Traditional approaches to industrial quality control, as
promoted by Walter A. Shewhart, W. Edwards Deming,
Joseph M. Juran and their followers, rely on control
charts.
 Typically, a minimum of ~30 batches is thought to be needed to
demonstrate that a process is in statistical control, but Donald J.
Wheeler suggests that as few as 10 batches may be adequate.
• Measurement uncertainty is small compared to batch variation.
• QbD initiatives are based largely on methods devised for controlling
the quality of widgets.
 Formal random sampling plans are well-defined.
 Experimental (non-continuous) data can be handled using
the ANOM (Analysis of Means) graphical method.
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Example Widget Batch Data
Batch 1
Batch 2
Batch 3
Batch 4
Batch 5
250
310
250
340
250
260
330
230
270
240
230
280
220
300
270
270
360
260
320
290
1-WAY ANOVA
Source of Variation
Between Batches
Within Batches
Total
SS
19830
9425
29255
df
4
15
19
MS
4957.5
628.3
F
P-value
7.89
0.0012
F crit
3.06
Wheeler DJ. Advanced Topics in Statistical Process Control. Knoxville TN: SPC Press . p. 374 (1995).
The example in the reference is analyzed graphically using Analysis of Means.
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Batches 2 & 4 were detectably higher than the Grand Average.
Batch 3 was detectably lower than the Grand Average.
Note that ANOM control limits are tighter than Average & Range chart limits for continuous processes.
Impact of Stability on Specs
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Now That’s Odd…
Batch 1
Batch 2
Batch 3
Batch 4
Batch 5
250
310
250
340
250
260
330
230
270
240
230
280
220
300
270
270
360
260
320
290
The data represent grams of coating per sample aliquot.
 Note that each value ends in ‘0’.
 The laboratory weighed the recovered coating using a balance
readable only to the nearest 0.01 kilogram.
 The smallest range within batches is 0.04 kg.
 The data granularity is too big; within-batch variation is on the
same order of magnitude as measurement uncertainty.
 The measurement tool is not capable of providing sufficient
accuracy and precision.
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Batch Variation in Biologics
Assay variation is the dominate factor in controlling the
quality of biologics, and batch variation takes a back
seat.
 Biologics are typically compared, batch by batch, to a certified
reference standard.
 From personal experience, variation between testing laboratories
participating in round-robin certification of new global standards
grossly exceeds in-house assay variability.
• Batch variation is swamped by measurement uncertainty.
• ICH recognized the need for a separate guideline (Q5C).
 Sampling plans are poorly defined
• Biologics traditionally were homogeneous solutions, so sampling
was not considered to be an issue.
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Example Bioassay Data
Table 4. FSH. LH and HCG immunoactivity in different HMG preparations.
Product
Drug
FSH
LH
HCG
product
immunoactivity immunoactivity immunoactivity
batch no.
lU/vial (relative lU/vial (relative lU/vial {relative
SD. n = 5)
SD. n = 5)
SD. n = 5)
Pergonal
0331206B
58.77 (2.2)
13.49(3.6)
3.39(1.7)
Humegon
43905119
65.12(1.7)
5.77(1.0)
6.86(1.8)
2nd WHO standard (FSH 54/LH 46)
77.72(5.0)
7.39 (2.4)
7.22 (4.8)
4th WHO standard (FSH 72/LH 70)
86.14(5.3)
3.82(1.8)
10.10(5.1)
Menopur
32509
74.17(1.9)
0.29 (5.2)
9.61 (2.3)
Menopur
32307
73.44 (3.9)
0.48(1.7)
9.05 (3.3)
Menopur
34104
82.62(1.3)
0.39(3.1)
11.06 (1.8)
The relative standard deviation is expressed as a percentage and is obtained by multiplying the standard deviation (per
batch) by 100 and dividing this value by the average (per batch).
Wolfenson C, Groisman J, Couto AS, Hedenfalk M, Cortvrindt RG, Smitz JE, Jespersen S. Batch-to-batch consistency of humanderived gonadotrophin preparations compared with recombinant preparations. Reprod Biomed Online. 2005 Apr;10(4):442-54.
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Now That’s Odd…
Two generations of the WHO standard were tested.
 The 2nd generation standard is certified to contain FSH 54 IU/ampoule
and LH 46 IU/ampoule. The 4th generation standard is certified to
contain FSH 71.9 (69.0-74.9 [95% fiducial limits]) IU/ampoule and LH
70.2 (61.7-80.0 [95% fiducial limits]) IU/ampoule. The values reported
are in comparison with the standards provided by the test kit vendor.
 The reported values for LH differ grossly from the certified values; the
FSH values are systematically high.
The reported values are overly precise; the last two digits in the
four-digit reported values are meaningless.
 The ‘uncertainty’ reported is the within day within analyst repeatability,
and does not include inter-day, inter-analyst, or most importantly,
interlaboratory uncertainty.
 There is insufficient evidence that any of the batches are different.
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Batch Variation in Stability Trials
Conventional experimental design (ICH Q1E) relies on a
small number of batches.
 Minimally 3 batches, and who even does more than the
minimum?
• Not enough batches are studied to demonstrate that the process is
in a state of statistical control, using the widget-making approach to
quality control.
• Recall that at least 10, and preferably 30 batches are required for
control charts.
 Measurement uncertainty is a substantial component of
variance, even for small molecule drugs.
 Sampling issues are not addressed in the guidance.
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Example Stability Batch Data
Batch Variation
101
100
99
% Potency
98
97
Batch 1
96
Batch 2
Batch 3
95
Batch 4
94
Batch 5
Outlier?
93
92
Batch 6
Outlying batch?
91
0
3
6
9
12
15
18
21
24
Time, months
Subbarao N, Huynh-Ba K. Evaluation of Stability Data. In: Huynh-Ba K (Ed) Handbook of Stability Testing in Pharmaceutical
Development. New York: Springer 266-267 (2009).
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Now That’s Odd…
Batch Variation
101
100
99
% Potency
98
97
Batch 1
96
Batch 2
Batch 3
95
Batch 4
94
Batch 5
93
Batch 6
92
91
0
3
6
9
12
15
18
21
24
Time, months
Batch 4 is much less stable than the other batches tested.
 But there is no reason not to believe that Batch 4 is just as
representative of the process as the other batches.
 Could the initial potency for Batch 4 have been mis-measured?
The 9-month result for batch 1 seems unusually low.
 But, after the fact, there is no way to determine if this low result
is a laboratory error (e.g., due to inadequate sample
preparation). We must include it.
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Batch Variation & Measurements
In widget-making, the accuracy and precision of
measurements, as demonstrated by Gage R&R studies,
is typically a minor component of total variance.
 Batch variation is easy to detect and measure.
In biologics manufacture, the accuracy and precision of
measurements, as demonstrated by interlaboratory
testing, is typically the dominant component of total
variance.
 Batch variation is difficult to detect and measure.
Conventional small molecule stability trials occupy a middle
ground.
 Batch variation is handled by crude conventions.
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Components of Variance
The relative importance of different sources
of variation in the measured quality of drug
products must be rigorously assessed in
order to define realistic release limits.
 Obtaining sufficient data is a challenge. R&D
(non-GMP) data and GMP data may need to
be combined to increase the reliability of our
assessment.
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Measurement Variation
Measurement uncertainty can be affected by :
 Within operators within equipment within labs within
days (repeatability).
 Between operators.
(intermediate
 Between equipment.
precision)
 Between days.
 Between labs (interlaboratory precision).
 Between dosage forms/strengths (sample
preparation, excipient interactions).
}
• Interactions with other components of measurement
uncertainty.
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Initial Product Variation
Initial uncertainty can be affected by:
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Manufacturing sites.
Manufacturing scale (equipment variation).
Dosage strength.
Packaging.
Between batches.
Homogeneity within batches.
Interactions between all of the above.
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Stability (Time-Dependent)
Variation
Degradation rate uncertainty can be affected by :
 Overall “average” rate of degradation
 Interaction with:
•
•
•
•
•
•
•
•
Manufacturing sites.
Manufacturing scale (equipment variation).
Dosage strength.
Packaging.
Environmental excursions (temperature, humidity).
Between batches.
Within batches.
Interactions between all of the above.
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Estimating Uncertainties
Not all of the factors enumerated in the
previous slides will have equal weight.
 We need to distinguish between “the vital few
and the useful many” (Juran).
• Pareto’s principle: 80% of the variation in product
quality is caused by 20% of the quality-impacting
factors.
 Designed experiments and observational
studies can provide insight.
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But Wait! There’s More!
What About Supply Chain Control?
Control of storage conditions during
manufacture and distribution (e.g.,
maintaining cold conditions for
temperature sensitive products) has been
a major recent concern.
 Proper design of stress degradation
experiments during product development and
monitoring of conditions during distribution
can address these issues.
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Unaddressed Supply Chain Issues
What about mail-order pharmacies?
 Regulatory expectations are that the supply chain
ends when the patient takes the drug, and not before
then. Medications are dispensed with storage
instructions.
 The U.S. Post office specifically states that control of
temperature is NOT provided, and that the shipper is
responsible for protection against temperature
extremes.
What about military deployments, where troops are
issued 180 day supplies of medications?
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Using Stress Experiments
In order to study uncertainty due to stability
issues, we need ways to SHRINK TIME,
because the issue is what will happen at
the end of shelf life.
 Properly designed stress degradation studies
can map the temperature×humidity design
space.
• In many cases, results for two years under ‘normal’
storage can be achieved in weeks.
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Error Budget
Given a set of final specifications, these
must be narrowed by amounts sufficient to
account for:
 Measurement uncertainty (guard banding).
 Stability-related changes in quality metrics,
especially within and between batch
uncertainty at end-of-shelf-life.
Whatever remains are the narrow limits that
define the release specifications.
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Fixed vs. Random Effects
We tend to do at least an adequate job of
designing experiments to study the effects of
‘fixed’ factors on product quality targets.
 That is, we can estimate bias [location].
We tend to do a poor job of designing experiments
to study the effects of ‘random’ factors on
variation of product quality.
 That is, we do not do enough to estimate uncertainty
or variation [scale]—of measurements, sampling or
degradation.
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Degrees of Freedom
95% Confidence Limits for Mean
35
35
Governs design
for fixed effects
(bias)
15
5
-5
μ
-15
-25
Governs design
for random effects
(uncertainty)
30
Standard Deviation Units
25
Standard Deviation Units
95% Confidence Limits for Standard
Deviation
-35
25
20
15
σ
10
5
0
0
5
10
15
20
25
30
35
40
45
50
0
5
Sample Size
15
20
25
30
35
40
45
50
Sample Size
For n = 3, C.L is 220% larger than for n = ∞
For n = 4, C.L is 62% larger than for n = ∞
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For n = 7, C.L is 220% larger than for n = ∞
For n = 14, C.L is 62% larger than for n = ∞
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Insurance
When estimates of a component of variance are
based on limited data, then:
 Consider meta-analysis combining data from nonGMP development studies with GMP data to increase
degrees of freedom.
 Inflate the estimated variance component by a factor
to account for the uncertainty of estimation of the
variance component to compensate for low degrees
of freedom.
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OOS and OOT
Failure to adequately estimate measurement uncertainty
and stability variation will result in many OOS and OOT
results.
 Either measurement uncertainty is underestimated, or
 Presumed shelf life is too long.
 Thus release specifications are too wide.
If a process is under control, OOS and OOT
results will be rare; contrapositively if OOS
and OOT results are not rare, the process
is not under control.
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Root Causes for Failure
Have all sources of variation been studied enough
to obtain a reliable estimate of their magnitude?
 HAVE YOU IDENTIFIED THE VITAL FEW?
Are factors in experimental designs assumed to be
fixed really random instead?
 ARE YOU ESTIMATING LOCATION OR SCALE?
Are release specifications based on sufficient
degrees of freedom for EACH factor?
 DO YOU REALLY HAVE ENOUGH DATA?
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But Really, Who Cares?
In a QbD world, we should aim to produce consistent product with
minimum variance.
 “While conformance to specifications is important, the fundamental
concept that some processes are predictable, while others are not,
makes the issue of conformity to specifications an issue which cannot
be addressed directly. If a process is predictable, then its conformity or
nonconformity will also be predictable. If a process is unpredictable,
then its conformity will be unpredictable, and anything we say about the
process will amount to little more than wishes and hopes.”
• Wheeler DJ. Advanced Topics in Statistical Process Control: The Power of
Shewhart’s Charts, Knoxville, TN: SPC Press, p. 187 (1995).
If we can reduce process variation, reduce product degradation
variation and reduce measurement uncertainty to low enough
levels through QbD, then setting release limits becomes moot.
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Discussion
σ→σ →σ →σ →σ →
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σ
37