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Management Awareness
ISPE PAT CoP D/A/CH
1.1 Objective
The objective of this document is to create awareness about the FDAs QbD/PAT initiative and its
benefits. It describes
• Drivers and Benefits
• How to benchmark QbD/PAT projects
• Case studies
Authorities view corresponds to Commercial Management view and the common goals
can be reached by QbD / PAT as an innovative way of thinking in manufacturing
pharmaceuticals.
Only efficient research of new drugs, optimized processes and dedicated quality control
procedures will provide in future affordable, safe & effective drugs for citizens. The
implementation of PAT principles and tools enables efficient manufacturing while maintaining
today’s quality standards.
Drug quality depends more on best development, production, storage and distribution strategies,
than on expanded quality testing. With PAT there will be a shift from lab based end product
quality testing to in-line, on-line or at-line testing.
Innovation transfer to routine production ensuring “state-of-the-art” manufacturing processes will
be accelerated by regulatory authorities.
• Time-to-approval
• Improved process understanding
• Reduced inspection frequency
PAT efforts could generate competitive advantages, i.e. better corporate image, increased
quality and efficient management of risks. Cost of manufacturing or QA could be decreased by
increasing productivity and better availability of production equipment. Moreover PAT offers the
opportunity for interdisciplinary communication (e.g. R&D, manufacturing, QA, QC, IT
departments).
Manufacturing processes could become more safe and flexible under PAT. A defined design
space (Quality by design) for production processes offers flexibility for the used raw material,
APIs and even process controls. Process understanding leads to an appropriate management of
variability and improved operational efficiency (e.g.“Lean Manufacturing”, “Right first time”
strategy). Real time release could help reducing time in warehouses of raw materials, final &
intermediate products or bulk (work in progress). PAT projects can start in single unit operations
or could cover the whole production site. Incremental deployment is enabled.
Improved communication between industry and the regulatory authorities is provided by FDA´s
PAT teams („pre-approval“ activities). By implementing PAT tools and principles industry is
prepared in case PAT becomes mandatory. International harmonisation by ICH guidelines Q 8 to
10 defines many PAT elements as today’s GMP standards.
plan
product
QbD
do
act
PAT
process
check
QbD/PAT
implications
Process
Organisation
Quality
Understanding
Management
IT
Technology
Personnel
3.1 Organization
3.1.1 Personnel
• Demand on qualification and/or skills of employees may change
PAT may have an impact on qualification profiles in respect to scientific data
analysis, statistics, process control, etc. Similar to implementing Six Sigma,
implementing a PAT program may require dedicated training on methods and
tools, including project management and statistics. (Probably at all levels of the
company comparable with the Six Sigma training structure - master black belts,
black belts, green belts, white belts?).
• Structural change within organization
There may be a need for implementation of a new department or restructuring of
departments to deal with the new demands.
Interaction and collaboration between departments and functions may need to be
increased (e.g. quality, regulatory, development, commercial production, etc.).
Contact to regulatory authorities may need to be intensified.
The implementation of PAT within the organizational structure requires
accountability, roles and responsibilities to be defined (Clearly defined process
owners, project managers, subject matter experts and process analysts).
Depending on the structure of the company, employees working for a PAT project
could stay members of different departments or be integrated in a separate PAT-
team or department.
3.1.2 Management
• Commitment of management:
Management has to be committed to PAT to deal with the early phase of PAT,
which could mean more investment.
In later phases, when processes are more flexible due to PAT elements,
companies will be able to maintain quality at lower cost, and will be prepared for
future demands from agencies and be on top of the trend.
• Define PAT and development strategy:
Define general approach.
Define team.
Define which processes or products should be subjected to PAT first.
Define goals and objectives and the expected benefits.
Plan and commit resources (personnel, program money, equipment).
PAT means a paradigm shift from black/grey box to white box processes.
The development strategy may need to be revised – therefore, the specific
requirements concerning PAT need to be analyzed.
• Risk concerning company:
If PAT is ignored, there may be a risk of getting behind the industry (competitive
disadvantage), a risk of image or business loss due to lower operational efficiency
in sustaining reproducible product quality.
• Management objectives:
Regular review of benchmarks helps to stay on top of the project.
• Outsourcing:
Outsourcing partners need to be chosen and reviewed very carefully.
Points to consider are:
- Their ability to perform projects according to PAT.
- Knowledge transfer (content, interfaces, patent, etc.).
- Define accountabilities, roles and responsibilities.
- Communicational structure.
There may be an increased need for secrecacy agreements and/or more detailed
contracts.
• Communication
Communication between all kinds of different partners (e.g. departments Ù
departments, vendor company Ù company, company Ù agencies, etc.) may need
to be intensified.
3.2 Process
The QbD/PAT approach links the four areas of Process Understanding, QA/QC, Technology and
IT together. This is the core of the QbD/PAT paradigm shift, linking these areas together.
The process is controlled and fully understood and the right data for real time release enables
continuous process verification and improvement via knowledge management.
3.2.2 QA/QC
• Specifications
Quality control testing will evolve from testing against a discrete specification
(pass/fail) to real-time comparison of process/product signatures against a
reference.
• QC testing
Parametric release and inline control could have an impact on QC headcount and
work.
There may be a necessity for additional verification of parameters and definition of
prerequisites for parametric release.
In order not to miss a slow deviation from expected requirements (e.g. raw
material, wear of material, etc.) additional controls may be needed.
• Continuous improvement
Under PAT, manufacturing processes are monitored and controlled online,
leading to continuous process improvements as opposed to static process
validation. Continuous improvement and control of design space will be
increasingly important.
• Validate equipment including the control cycle
In contrast to the common validation approach, where testing the functionality of
the immediate equipment was sufficient, with PAT the complete control cycle of
the equipment has to be included.
3.2.3 Technology
• Continuous production
New equipment may be needed to enhance data acquisition and process
understanding. Better knowledge of the process could lead to continuous
production and faster release.
Due to design space, production equipment could be used more flexible.
• Availability of suitable sensors/methods
After identification of critical process parameters availability of suitable sensors
and methods has to be verified.
• Interface systems engineering Ù product engineering
Since all parameters of a process have to be well understood system engineers
and product engineers will probably have to work together more closely.
4.1 Introduction
Identification and evaluation of benchmarking parameters concerning PAT applications is
important for various aspects:
• to raise acceptance in the management
• to proof the maturity of projects
• for monitoring project progress
Following categories have been defined for this assessment already, and may be extended on
the user’s discretion:
• Quality (cat. 1)
• Process (cat. 2)
• Risk (cat. 3)
• Cost (cat. 4)
• Personnel (cat. 5)
• Tools (cat. 6)
• Time (cat. 7)
• Validation (cat. 8)
• Organization (cat. 9)
• Regulatory (cat. 10)
4.2 Questionnaires
You will find the blank and completed questionaires in the appendix.
Case C
Case A
Case B
Degree of QbD/PAT
4.3.1 Quality
Positive effects depend on the degree of the PAT implementation as following
• OOS reduction
• Better quality definition and analysis methods
• Reduction of complaints and recalls
4.3.2 Process
In all investigated case studies the general process understanding has strongly increased, e.g.
by optimized adjustment of known process parameters. In some case studies also new CPPs
were identified and used for advanced process control.
In most cases the process cycle time was reduced significantly and the productivity was
increased.
Introduction and implementation of new technologies for process automation (including sensors,
analytical devices and process control technologies) isn’t a mandatory prerequisite for QbD/PAT.
QbD can also be achieved by existing process and control equipment.
The benefits of implementing QbD/PAT in the process has been estimated very positive.
4.3.4 Cost
Most of the case studies can not answer to the question of ROI, only one case claims a ROI of
less than one year. For all other cases it is too early for any calculation.
As far as there are experiences, less rejected batches, less deviations increased yield higher
OOE, less consumables, less waste and reworks are reported.
4.3.5 Personnel
Up to now there is no reduction in personnel: Production is less lab intensive due to a higher
degree of automation, but the personnel has shifted its tasks to implement and improve PAT.
The mind change encourages communication between different depertments. A better process
understanding is obtained. There are hints to a slight increase in personnel security.
4.3.6 Tools
A clear result of the investigation is that more process data is recorded, analyzed and stored.
The data is additionally used within the batch documentation. In most cases the data is used for
advanced process control and the prediction of process deviations.
Applied analytical methods: e.g. NIR, MIR, Raman, laser diffraction, mass spectroscopy,
accelerated dissolution testing.
Applied statistical methods: e.g. MVDA, DMAIC, DoE.
4.3.7 Time
Summarizing, faster processes are reported:
• Higher utilization of resources.
• Reduced lead time by reduced intermediate off-line testing.
• Faster decisions for on-line quality assessment, faster and earlier decisions on waste
material.
• Due to automated data acquisition, shorter transition time from raw data to meaningful
process information.
• Material variability is detected earlier.
4.3.8 Validation
In total a lower effort for validation is expected but more effort has to be spend for facility,
equipment and software validation during PAT implementation.
4.3.10 Regulatory
Regulatory issues have a strong impact on:
• Frequency of contacts and communication (scientific based) with regulatory bodies.
• Earlier and more often contact before and during implementation phase.
• The kind of documentation will be changed (more precise and deeper science based,
earlier documentation during design expected).
• Positive impact on change control is expected.
4.4 Summary
The aspects of quality, risk, validation and regulatory can be summarized as positive experience
when PAT is professionally implemented. Companies with lower implementation expertise have
slightly positive expectations, but needs more experiences.
Process understanding has strongly increased as well as the interdisciplinary communication
between departments.
Generally speaking, a lot more data are stored due to implementation of PAT technologies; and
we notice that a broad variety of sensors is used.
Currently most of the ongoing PAT projects are not mature enough for any sophisticated
calculation of cost benefits. Experiences report about better indirect costs, like less rejected
batches, higher yields etc.
Regarding to costs, benefits are claimed more in terms of higher yield, reduced cycle times and
less rejections/ reworks than in less personnel; there is a shift in tasks for the same staff.
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page 18 of 67
5 Appendix: Structured Catalogue of Standardised Questions with Benchmarking
1 3 Quality Quality tests In which kind has QUALITY CONTROL See above Not applicable
the process of all processes and tests
quality control that evaluate the status
changed? quo versus
specifications and
requirements
1 4 Quality complaints/ Has changed the No, not yet Not applicable
recalls amount of
complaints and
recalls of products
with RTR/PR (Real
Time
Release/Parametric
Release)?
1 5 Quality Product Is the product No, future impact No, not yet
specification specification more possible
science based? Is (narrower ranges)
there an impact to
the product
specification?
0 1 Type of What is the Prod Final release R&D The project is in R&D
Project environment of the drug product R&D at the
project? moment, but will
go right through
to production.
0 2 Status of the What phase is the Ong Pending start-up Ong At the moment othe Method successful
project project in? inspection the first tests in r established for scale
industrial scale up. No products for
take place scale up at the
(looking for proof moment. No benefit
of concept). for usage of “old”
However there is products during
already routine production.
knowledge gained
out of it.
1 1 Right the first Has the fraction of Right first time 4 Additional testing, - Not yet in 1 At the moment - No relevant products
time the products that percentage of the during commercial there is only at the moment.
has been produced products at the manufacturing, production mode, monitoring of
right the first time point of still end product but this is moisture inside
changed? manufacture that testing, more expected, due to the dryer. The
are delivered right knowledge. implementation of expectation is that
first time with no Improvement: No feedback control. at the beginning
defects surprises during there will be an
end product increase of
testing, only rejects, because
confirmation, Only the process is
1 out of 500 out of more closely
spec batches. watched. Then
through CAPA,
eventually the
process will
become more
robust and “right
the first time” will
increase.
1 2 Quality Did the quality Quality process e.g. risk assessment 4 Still end product - PAT to replace 3 Not yet (still in 2
processes processes change all processes that testing. But more laboratory proof of concept –
in the organization regulate all quality process release test therefore decision
with PAT related activities in knowledge leads will be later), but it
implementation? an organization to less surprises is expected, that
during the final PAT will add a
end product tool for faster
testing. quality decision.
1 3 Quality tests In which kind has Quality control Testing and definition Additional On-In- Real-time release Objective and No change.
the process of all processes and of specifications, Real- At-line testing replacing lab faster quality
quality control tests that evaluate time-release implemented. The assay decision
changed? the status quo existing is still
versus there – No
specifications and regulatory change
requirements and still the same
filing! No change
management
necessary!
1 4 Complaints/re Did you see a 1 No RTR - Not yet 1 Not yet – the - No PTR/PR
calls change in the implemented project has not established.
amount of yet come to this
complaints and stage.
recalls of products
with RTR/PR
(Real Time
Release /
Parametric
Release)?
1 5 Product Is there an impact 1 No, still the same - Release specs 1 No – because 1
specification to the product MBR. consistent, added PAT will impact
specification? Guard band for the process
environmental specification,
variability rather than the
product
specification.
1 6 Product Is the product 1 The new - Yes, the use of 1 The process - No change in
specification specification more analytical tests the PAT release specification is product specification.
science based? are more science test was integral more science
based, but full to discussions based (specific to
science based about appropriate vaccines,
approach is only specifications. because of very
for new products diluted active
under ingredients)
development.
1 7 Product Is the development 5 Change in the - PAT for real-time 1 See above - No product in
specification of product future with the monitoring of development at the
R&D specification new filings under quality moment.
changed with new PAT FDA
PAT? approach!
1 8 OOS Did you see a 5 Dramatic - Not yet 1 No – not far 1
change in the reduction. The enough at the
number of OOS project brought moment.
incidences? OOS nearly to 0!
Process
improvement!
2 1 Cycle time Has the cycle time Cycle time 5 Yes, streamlined - Not anticipated to 3 No feedback at 1
changed? this is the total time the process, change the moment, but
from commencing much shorter significantly, but the aim is yes –
manufacture to cycle times, there will be lower (faster
delivering products proved by some decrease quality decision)
to the customer evaluations! arising from the
which in many elimination of
cases is the factory intermediate off-
warehouse line testing
(particularly
during start-up).
2 2 Productivity Did a better 5 Key point/benefit, - Expected to 3 YES - Not applicable
increase understanding of WIP is no longer provide better
the variability of a in unknown control and
measurement status. provide process
result in an earlier understanding,
transition to the but not increased
next unit productivity
operation?
2 3 Process Were new 2 Yes, but the same - New sources of 5 Yes 3
parameters important process parameters were variability have
parameters or identified. been identified,
correlations but not yet
between process characterized
parameters
identified?
2 4 Process Were any known Acceptance criteria 5 Same parameters - PAT used for 5 YES 1
parameters process much more feedback control
parameters precise, much of filling
adjusted? better process equipment.
understanding
2 5 Implementatio Were new 1 Still the same - First commercial 2 Yes at clinical 1 Not yet.
n of new technologies in the process, new installation of the scale. The
technologies process analytical control robustness of the
implemented? technologies technology process has to be
implemented anywhere in the verified before the
successfully world (NMR on information is
solids) given to the
authorities.
2 6 Process Was process i.e. usage of structured 5 Yes - Yes, including 4 4
understanding understanding data management, insight into
increased? statistical methods previously
undetected
variability.
2 7 Process Did better 5 Cross product - Once new source 2 No because 2
understanding understanding of a effects, shorter of variability is except of NIR, the
process help in process characterized, it technologies are
other processes? optimization for should have too difficult to
other products impact on other transfer.
and shorter time solid filling lines,
to market effect. and the
technology may
help in setting
API specifications
for subsequent
products.
2 8 Yield Is the yield higher - 3 for the process - No. 1 Would not sell Pat 1
after PAT than itself and 5 for no as a project that
before? more lost will increase yield.
batches!! PAT is more a
tool to increase
compliance and
quality, rather
than yield.
2 9 Process Did you find 1 No changes in the - No 4 Yes 4 Part of the process
control additional process control could be controlled
possibilities to by NIR.
control the
process?
3 1 Risk Was the PAT 5 Risk assessment - No. A rigorous 3 There was a good 3
assessment project a result of a made for market FMEA was knowledge of the
risk assessment? supply – developed as process – Risk
Economic Risk part of the PAT Analysis was
assessment! installation. already done
But the
Assessment was
made already 15
years ago.
3 2 Risk Did the PAT 1 No additional in - Yes. 1 No because it 2
assessment project initiate risk this project. Other was already done
assessments? projects with Risk for process
assessment validation
already before the
PAT initiative.
Confirmation of
the chosen
approach.
3 3 Risk reduction Did the PAT 5 Yes, supply is - Anticipated this 4 Yes 5
project reduce with the new will be the case.
risks? more robust and
secured!!
4 1 Overall Has the OEE Overall equipment Example entry 4 Streamlined the - Anticipated that 1 Increase, return 1
equipment changed? effectiveness manufacturing this will be the on investment is
effectiveness This measures case questionable.
(OEE) how effectively the There is a
manufacturing question of what
equipment is used. is more important:
It is a product of quality and
the product rate compliance or
multiplied by the costs.
quality rate
multiplied by the
plant availability. A
figure of 100%
implies that the
plant is running flat
out every hour of
the day making
perfect products
4 2 Cost savings Where did you Personnel, equipment, Minimized Expected savings Cost could be No reduction in costs
reduce costs? QC, raw material etc. WIP/Work in in recovery of saved due to till now.
Process partial lots and faster decision on
Less rejected elimination (or at good/bad product.
batches least decrease) in
off-line testing.
Early detection of
variability of raw
material.
New detected /
invented critical
parameter
resulted in a new
parameter for the
specification. - >
Hugh saving by
early detection
Minimizing QC
testing by moving
it to the plant
4 3 Return on What is the period Investment phase Less than 1 year Has not been No answer at the
Investment until break even of calculated. Can moment – but is
the PAT project? be performed that really the
once the system purpose of PAT?
is operational.
5 1 Personnel Did you improve 5 Yes - 100% quality 1 No - Not applicable.
security the operator or/and assessment is
product safety? anticipated to
improve product
safety and
efficacy
5 2 Automation Was number of None 1 Same staff - Anticipated 2 What’s the cost of - Not applicable.
versus human personnel outcome, based ownership? PAT
interaction reduced? on PAT being usually means
less labor more technology
intensive at final – so there would
deployment. be more likely a
Some personnel change of skills,
resource will be rather than an
relocated, rather objective
than eliminated, decrease of
but as this is a people.
new process, all
headcount are
projected, rather
than actual.
6 1 Information / Can the The information of 5 The data is - Expected to be 1 No – but not far 5
data additional/gained the process can be gathered in a the case enough at the
management information be used on other special database moment.
used in other areas levels or in other incl. a feedback to
as well? areas as well R&D.
6 2 Information / Do you store more Data management 5 More valuable - Additional data 4 far more - Not applicable.
data or less of The data you store information collected, but
management information? while processing fully automated,
the product whereas
traditional
process was
more labor
intensive
6 3 Information / Did you change PAT data in Batch Incorporated 4 Yes – adapt some Not applicable.
data the documentation Documentation directly into DCS servers
management storage structure? added. PAT data
is in a separate
DB and printed
out.
6 4 Process Are additional For example online 5 Yes new - Much higher data 4 Yes – more long 1
control analytical methods exploitation of data analytical density, but no term quality input
used to predict with neural methods were additional - trend analysis
process networks invented and methods aside
deviations? used for the from PAT
process control.
6 5 Methods Which tools and i.e. as result of Method: NIR – Not clear in the Plasma system, Mass spectrometry
methods did you automation, usage of API content objective of this NIR, two other
use in the PAT methods question. technologies, but
Method:
project? no further
Accelerated
dissolution - film description
quality because of
Intellectual
Method: Laser Property.
defraction -
Particle size
measurement
7 1 On time in full Has the on time in On time in full Example entry 4 - Likely to increase 3 No feedback at - Not applicable.
delivery full delivery delivery due to real-time the moment –
changed? This is the quality target is to
percentage of assessment increase
orders that are
satisfied on time in
full, with zero
defects. Note that
if there is one
defect in an order,
the OTIF is zero
percent
7 2 Time to Did a better 5 Yes, main project - Will probably 1 PAT will not be a - Not applicable.
market understanding of driver. Also cross actually add big driver to
the process reduce product benefits resources initially reduce time to
the number of realized. to understand market. It will
iterations in and characterize make the process
process sensor response more robust, but
development (e.g. and process this will not have
scaling up)? variability a great impact on
timing.
7 3 Time to Is the efficiency in - Can not be - Yet to be 4 Yes - Not applicable.
market licensing answered yet, determined
processes due to ongoing
(submission submissions
approval) higher under new FDA
after PAT? QbD PAT
approach.
8 1 Process/para What relief in 2 Still traditional - Not yet known 4 - Not applicable.
meter validation efforts validation. There
changes did you notice? is more
confidence in the
Validation
approach, but no
relief in the
validation efforts.
8 2 Process/para Did you change e.g. switch of 1 No change. - Added PAT 1 Not yet – but will - Not yet.
meter the validation responsibilities in the characterization be
changes approach? organization to process
validation
8 3 (Re)validation Did you reduce the Effort in 1 Still the same - Yet to be - Not far enough – 1
effort effort for (Re)validation approach. determined target, but no
(re)validation (how (Re)validation is a feedback.
much in regular
percentage)? requirement. The
effort is the
complete work you
must do
(manpower,
paperwork, data
generation etc.) to
reinstate the
validated status
10 1 Regulatory Has PAT an 5 Following the new - PAT installation 1 No, there is not 3
requirements impact on the FDA Risk based is facilitating much difference
awareness of and PAT oriented discussion with in filing a PAT
regulatory paradigm change. regulatory application,
requirements? agencies because the
regarding description of the
changing process is not so
expectations for big. CMC section
submissions, will be bigger
particularly with
respect to risk
management.
10 2 Regulatory Did PAT have an 5 Submission - Expected to be - Not yet - Not applicable.
requirements impact on change ongoing the case
control processes according to new
with regulatory PAT Guidance.
bodies?
10 3 Audits Are the 5 Yes, lot of - yes 3 It depends on - Not applicable.
discussions with interactive authorities and
regulatory bodies discussions on a inspector.
more scientific? high scientific
level.
10 4 Audits Has the frequency 1 No change - Anticipated to 1 No 1
of audits changed? decrease, but
has not yet
transpired.
10 5 Docu- Has PAT an 5 More precise - Documentation 3 Yes 3
mentation influence on the Documents in quality hasn’t
quality of R&D, justification changed, but
documentation for docs and additional
generated during better process development
development? description, better data was
validation of the required.
CPP ranges,
explanation of
the process and
the process
understanding
increased and is
more extensive
0 2 Status of the What phase is the Ong As of April, 2005 Ong Study phase
project project in?
1 1 Right the first Has the fraction of Right first time - Not disclosed Not yet
time the products that percentage of the implemented in
has been produced products at the routine production
right the first time point of
changed? manufacture that
are delivered right
first time with no
defects
1 2 Quality Did the quality Quality process e.g. risk assessment 4 Systems remain 1
processes processes change all processes that the same, but
in the organization regulate all quality adapted to reflect
with PAT related activities in a risk-based
implementation? an organization approach
2 1 Cycle time Has the cycle time Cycle time 4 Not disclosed – 5 Not yet – but is
changed? this is the total time only mention was expected
from commencing that analytical
manufacture to testing cycle time
delivering products was reduced.
to the customer
which in many
cases is the factory
warehouse
2 2 Productivity Did a better 1 Not disclosed 5 Not yet – but is
increase understanding of expected
the variability of a
measurement
result in an earlier
transition to the
next unit
operation?
2 3 Process Were new 4 It was disclosed Not yet
parameters important process that material
parameters or attributes and
correlations select process
between process parameters, in
parameters combination,
identified? affected the
dissolution rate of
the product.
Other
relationships were
not disclosed.