EMA Publishes Concept Paper on Process Validation in Protein Products
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This concept paper addresses the need to develop guidance on process validation of biotechnology derived active substances.
Guidelines related to the quality of Biotechnological/Biological products have been developed at the EU level, and several documents have been harmonised through the ICH process. However, these documents do not satisfactorily address the specific aspects of validation and evaluation for biotechnology derived products.
Validation and evaluation are essential concepts when setting the manufacturing process steps of biotechnology derived products. The evaluation/validation data provide essential information on the reproducibility and robustness of the process steps and are an important element to guarantee consistency in the quality of the product. The data encompass studies that are performed on product and process steps representative of the commercial process and may cover a wide range of situations and experiments (e.g. full scale, pilot scale, laboratory scale, scaled-down), depending on the objectives of the evaluation/validation studies carried out during development (e.g. consistency, viral safety evaluation, process-related impurity clearance).
The currently approved guidelines address the control of Biotechnological/Biological products (i.e. ICH Q6B on specification and ICH Q5C on stability), and/or some specific issues or aspects of the process (i.e. ICH Q5A on viral safety, ICH Q5B on genetic stability, ICH Q5D on cell substrates and ICH Q5E on comparability). ICH Q11, currently under development, is aimed at addressing the description, development, control strategy and process evaluation/validation of active substances of biotechnological and chemical origins. Although ICH Q5 and ICH Q11 documents address several important aspects or concepts relating to the evaluation/validation for medicinal products containing biotechnology derived proteins as active substance, as illustrated above there is no guidance to cover other aspects such as process- and product-related impurity clearance (e.g. host cell proteins, DNA), column/membrane sanitization and life time, hold time, reprocessing, pooling of intermediates and selection of batches to be included in evaluation/validation studies. All these elements do contribute to a good understanding of the process and the resulting product, and are needed for the assessors at the time of evaluation of a marketing authorisation application.
It is well acknowledged that ICH Q8, Q9 and Q10 guidelines are progressively being implemented in the routine practice of manufacturers and marketing authorisation holders. However, whereas these guidelines provide a new approach on the management of quality and build up the quality at every step of the life cycle of a medicinal product, they do not provide practical recommendations on the necessary evaluation/validation studies to be filed on these specific aspects (new application or variations).
Damien Bové is THE Drug Development and Regulatory Consultant (pharmaceutical or biotechnology), I work with my clients to define a drug development target, define a drug development strategy, define a regulatory strategy or define a commercial strategy. Our clients are generally raising funds or looking to license out their technology and we help them achieve it. If you want to know more don’t hesitate to get in touch.
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