Title: Quality%20Management%20for%2021st%20Century
1Quality Management for 21st Century
S. Srinivasan CEO Managing Director Matrix
Laboratories Limited
2Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
3Indian Pharmaceutical Companies geared up for
global market
- Current size of the global Pharma market is
around US 800 billion - Generic market US 93 billion
- the API market US 37 billion
- (Source Espicom business intelligence)
- Global demand of APIs is expected to increase at
CAGR of over 8 over the next 5 years (Source
Chemical Pharmaceutical Association (CPA)) - A recent study by EY indicates projected growth
in Pharma outsourcing out of India of over 40. - India projected as an excellent destination for
cost efficiency in manufacturing, coupled with
strong supply of skilled manpower, in comparison
to China, Eastern Europe, Puerto Rico, Singapore
Ireland
4Indian Pharmaceutical Companies geared up for
global market
- India has maximum number of USFDA approved plants
outside the US and last few years filed the
maximum number of DMFs. - Indian companies play a predominant role in the
WHO pre-qualification programme related to
Malaria, TB and HIV/AIDS. - Indian pharmaceutical and API players are well
positioned to take advantage of this market
opportunity. - Indian companies have created good infrastructure
with cGMP compliant plants over the last decade.
5Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
6Quality Management for 21st Century
- An integrated quality system should cross into
all areas of operations. - QMS to be designed to assure quality into the
manufacturing and control processes. - ICH Q10 is not intended to create any new
expectation beyond current regulatory
requirements. This guideline has been formed by
integrating GMP requirements (ICHQ7) and ISO QMS
guidelines. It serves as a bridge between
regional requirements, facilitating harmonization
of pharmaceutical quality system. - Implementation of ICH Q10 should facilitate
innovation and continual improvement and
strengthen the link between pharmaceutical
development and manufacturing activities.
7Quality Management for 21st Century
- Main objectives of Q10 are
-
- To achieve product realization
- Establish and maintain a state of control, and
- Facilitate continual improvement
- Pharmaceutical quality system should include the
following elements - -
- Process performance and product quality
monitoring - Corrective and preventive actions
- Change management and management review
- Key performance indicators should be identified
and used to monitor effectiveness of processes.
These indicators can be derived during the
development process and also from manufacturing
experience. They can be used as enablers for
continual improvement. -
8Quality Management for 21st Century
The quality management system presents continuous
validation -concept to replace the current
three-batch process validation concept, i.e. move
from paradigm of testing to assure quality to
designing to assure quality and increase
process capability to minimize risk. Implementati
on of this framework will place tremendous
responsibility on the pharmaceutical
manufacturers to have the Operations and Quality
teams well-trained in quality management
initiatives In integrated QMS, there is an
interplay of several ICH guidelines - - ICHQ8
on Product Development - ICHQ9 on Quality Risk
Management
9Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
10Quality Risk Management
- ICH Q9 should serve as a foundation and
complement existing quality practices, standards
and guidelines within the pharmaceutical
industry. - Appropriate use of quality risk management can
facilitate regulatory compliance to a substantial
degree and also improve quality of communication
between industry and regulators. - A rational approach to risk management has to
begin with the question What is the impact on
the product?
11Quality Risk Management
- This guideline provides a framework that may be
applied to all aspects of pharmaceutical
business, including -
- development, manufacturing and distribution
- inspection and submission /review processes
throughout the lifecycle of drug substances,
biological and biotechnological products and - use of raw materials, solvents, excipients,
packaging and labeling materials.
12Quality Risk Management
- Risk Management is about
- knowing our processes (manufacturing and
business) - understanding what is truly important
- not spending time on a low risk activity,
process, event or system because it just doesnt
matter! - focusing our money, time, energy and people on
the things that are really important - focusing our efforts and resources on the things
that provide quality assurance to our customers - Risk Management is not about
- making do with insufficient time, money or people
- providing an excuse not to do the right things
- deciding what to do based on what might be
observed during an inspection
13Quality Risk Management
- It is imperative therefore, that we as API
manufacturers are able to and perform a
scientific and practical risk management process
as a part of the quality management and - document the observations
- the actions and other related details based on
current knowledge about assessing the probability - the severity and detectability of the risk.
- Output of a risk assessment could either be a
quantitative estimate of risk or a qualitative
description of a range of risks.
14Quality Risk Management
Based on the risk analysis, one could arrive at
appropriate risk control measures to reduce and
/or accept risks. Training of industry
personnel in quality risk management process
provides for greater understanding of decision
making processes and builds confidence in quality
risk management outcomes.
15Example 1 Quality Risk Management
- Recent examples of improper evaluation of
manufacturing processes - (Source http//www.emea.europa.eu/humandocs/PDFs
/EPAR/Viracept/Viracept-H-164-Z-109-AR.pdf) - Nelfinavir
- Europe wide recall of the HIV drug Nelfinavir
- Patients reported strange smell on the tablets
- Investigation revealed high level of Ethyl
Mesylate (EMS) a potential genotoxic impurity - Investigation at the manufacturing plant
identified ethanol contamination in a holding
tank of Methane Sulphonic Acid (MMS) - Ethanol was used as a cleaning solvent which was
not part of a regular procedure - Residual ethanol got converted to EMS in presence
of MMS - Lack of knowledge understanding of the
manufacturing process
16Example 2 Quality Risk Management
- Recent examples of improper evaluation of
manufacturing processes - (Source http//www.ibc-asia.com/GenericsAsia/Day
201/Ron20Tomer.pdf) - Terbinafine
- A potential impurity was identified in the
manufacturing process of the API - Launch of the Generic version was delayed due to
lack of knowledge - Impurity was expected to be generated due to two
starting materials (Acrolein and PCl5) - EDQM initially set a limit of 6 ppm and after
additional studies fixed the limit at 500 ppm - This impurity now appears as a listed impurity in
the EP monograph
17Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
18Product Development
- Another integral part of the new quality
management system is ICHQ8 on pharmaceutical
development. - The aim of pharmaceutical development is to
design a quality product and its manufacturing
process to consistently deliver the intended
performance of the product. - The information and knowledge gained from
pharmaceutical development and manufacturing
experience provide scientific understanding to
support the establishment of specifications and
manufacturing control. - Information from pharmaceutical development
studies can be a basis for Quality Risk Management
19Product Development
- Changes in formulation and manufacturing
processes during development and lifecycle
management are opportunities to gain additional
knowledge. - Movement out of the controls window should be
considered a change and would normally initiate a
regulatory post-approval change process.
20Example 3 Trend Analysis before CAPA
21Example 3 Trend Analysis after CAPA
22Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
23Process Analytical Technology (PAT)
- Process analytical technology approach should
encourage voluntary development and
implementation of innovative approaches to
pharmaceutical manufacturing and quality
assurance. - Many new technologies that provide information on
physical, chemical, biological characteristics of
materials will help in improving process
understanding, predict quality and performance. - Regulatory expectations are so high that
manufacturers are expected to use such
technologies to improve efficiency and
effectiveness of process design, manufacturing
controls and quality assurance.
24Process Analytical Technology (PAT)
- Gains in quality and efficiency from PAT could
vary and are likely to come from - reducing production cycle times by using on-line
measurements and controls - preventing rejects, scrap and re-processing
- real time release
- increased automation to improve operator safety
and reduce human errors - improving energy and material use and increasing
capacity - facilitating continuous processing to improve
efficiency and manage variability - The integrated quality system orientation affords
a flexible regulatory approach for implementation
of PAT under the facilities own quality system
25Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
26Regulatory Review
- Regional differences in the regulatory review
processes such as filing of changes are adding
complexity to manufacturers during the product
life cycle. - Now considerable emphasis is being placed on
- Assessment of possible Genotoxic impurities
- Crystal characteristics
- Polymorphism
- Enantiomeric purity besides residual solvents,
organic and inorganic impurities - Metal catalytic residues
27Regulatory Review
- The regional differences in the regulations and
the different requirements for the same monograph
as per different Pharmacopoeias pose its own
challenge to the Industry. - Compelling necessity to develop a bank of
reference standards - Increasing emphasis by the WHO and its
expectation for the APIs for WHO markets to be
compliant with the international pharmacopoeia,
has raised an additional point of complexity. - One hopes that WHO also joins the initiative of
harmonization and international pharmacopoeia
gets harmonized with other standards of
reference. - It is important for the manufacturers to design
and develop their operations with the aim of
avoiding excessive changes to their products
during its lifecycle. - This would save precious time as well as
resources for the organization.
28Indian Pharmaceutical Companies geared up for
global market Quality Management for 21st
Century Quality Risk Management Product
Development Process Analytical Technology
(PAT) Regulatory Review Conclusion
29Conclusion
Quality Guru Deming has the following to say on
variability inspection - Depending on
inspection is like treating a symptom while the
disease is killing you. The need for inspection
results from excessive variability in the
process. The disease is variability. Ceasing
dependence on inspection means you must
understand your processes so well that you can
predict the quality of their output from upstream
activities and measurements. To accomplish this,
you must have a thorough understanding of the
sources of variation in your processes and then
work toward reducing the variation. Ceasing
dependence on inspection forces you to reduce
variability.
30Conclusion
To conclude, the API industry needs to evolve to
a desired quality system
Present Focus Desired Focus
Documentation Trend Data analysis
Have SOPs Understand parameters that are critical to quality attributes
Follow SOPs Measure process capability
Validate process Perform continuous quality verification
Meet specifications dont change Undertake continuous improvement
31Thank you