complying+with+cgmp+during+phase+1
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Approaches to Complying with cGMP
During Phase 1
Guidance for Industry INDs
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FDA Guidance for Phase 1 CTM
Provide guidance for producing Phase 1materials
Covers Investigational Drugs and
Biologics Establishes rules for applying quality
control principles
Facilitate Phase 1 trials while protecting
study subjects Covers small or lab scale production
Link to FDA Guidance
http://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm070273.pdfhttp://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm070273.pdf -
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Requirements - QC Procedures
Written procedures that are well defined
Equipment that is adequately controlled
Data from production, including testing,that are accurately and consistentlyrecorded
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Requirements - cGMP Documentation
Personnel and training
QC plan
Facility and Equipment procedures Control of Components
Written Procedures for Production
Change Control
Laboratory Controls Container Closure and Labeling Controls
Distribution Documentation
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Requirements - Record Keeping
Equipment maintenance and calibration
Production records and related analytical
test records Distribution records
All quality control functions
Component records Maintain records for 2 years after trial
completed
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GMP Batches in Non-GMP Areas
InstantGMP complies with FDAguidance for Phase 1 supplies.
CROs can do GMP work in sameequipment/lab as development work
Tox batch can be made GMP and usedin Phase 1 trial
Medical device developers can produceGMP finished products
http://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm070273.pdfhttp://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm070273.pdfhttp://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm070273.pdfhttp://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm070273.pdf -
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Scalable Solution
InstantGMP
From small developmentbatches
To full productionbatches
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cGMP: Challenges of Traditional Systems
R&D contract manufacturing is a complex process.
Wide array of regulatory requirements
Reality of dealing with continual changes as projects progress
High time and cost to set up quality system
Long cycle times for QA review and corrections
Training and compliance to SOPs is lengthy
Documentation coordination and data tracking is laborious
InstantGMP is our manufacturing service that has beenbuilt from the ground up to meet these challenges
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InstantGMP - A new approach to
contract manufacturing. Seamlessly incorporate everything necessary in
one place where it is visible all the time toeveryone via cloud-based application.
Provides flexibility, speed, real-time access toinformation.
Uses proven quality procedures and efficient
data flow.
Accelerates startup and rapidly reacts tochanges and delays without endangeringtimelines.
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InstantGMPTM
A unique R&D contract manufacturingservice that:Allows sponsors to view and interact with
manufacturing information in real time.
Can rapidly react to changes and delayswithout missing a deadline.
Because: It offers flexibility, speed, proven procedures,
access to real-time information and efficientdata flow at all points during themanufacturing process.
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InstantGMP - The Manufacturing
Application Foundation of CFR 21 Part 11-compliant software
and an all-encompassing, paperless qualitysystem
Internet-based infrastructure
Data is automatically visible to all decision-
makers at the same time
Eliminates delays created by traditional linearprocesses
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Comprehensive Solutions to cGMP
Information is automatically updated everywhere in the system,
Sponsors can access their projects from any Internet-connectedcomputer
InstantGMP
Production
Specs Purchasing
Inventory Training
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Advantages
InstantGMP
TM
enhances control, visibility,efficiency and compliance of the regulated
Life Science manufacturing process.
QASponsor
Project TeamPurchasing
Manufacturing
Cloud
Server
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ControlAutomated rules and entries, that are based on the SOPs, are
integrated in the system.
Some of the many features:
System assigns lot numbers upon receipt.
QA enters and controls raw material status based on QC Labinput.
Can only issue approved raw materials.
Reconcile Lot receipts, issues and returns.
Predefined values for entries in batch records.
Electronic signatures.
Issues Requisitions.
Limited access.
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Batch Production
Digital signature with date stampDrop down lists toensure accuracy
Control
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Visibility Available via the internet Review and sign records from any location
Access controlled by firewall protection
Manage access for employees, partners and sponsors
Manufacturing
Remote Site Remote Site
ANYWHEREANY TIME
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VisibilityReview all areas of batch record via tabs:Cover Page, Approvals Page, In Process Tests, Bill of MaterialsEquipment List and Manufacturing Instructions Steps
Review and update manufacturingsteps online
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Efficiency
QC, QA, Warehouse, Purchasing, Inventory and
Manufacturing activities and records are linked.
Some of the many features:
Standard specs, tests and vendors are reusable within thesystem
Create Purchase Orders for approved vendors
Receive materials and manage inventory
Automated Master and Batch Production Record copies
BOM created as part of record Inventory depletes as batch is being run
Documents are transmitted electronically and signedelectronically.
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EfficiencyVendors, Tests and Methods need to be added only once
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QA Compliance
cGMP compliance controls are built into the system.
Some of the many features:
Limited access based on user/role
Materials quarantine/restricted until QA approval
Required signatures at specified batch record steps
Component reconciliation
Training records
Specification version control
Complete automated audit trail
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QA Compliance
Materials need to beIn an approved status tobe used in batches
Materials need to have qualifiedVendors before being used in batches
Only a Quality Manager can update a materials status
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Process Flow
Preparation for Manufacturing
No
VendorQualification
API, excipientsand components
identified
YesPM Initiates
Project
VendorsQualified?
ProjectDefinitionCompleted
QualityManager
ProjectManager
SpecsApproved?
Assign Part #s,tests, methods,
Specs
Select Personneland Roles
Yes
QualityManager
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Process FlowMaterial Management
IssuePurchase Order
MaterialsIn DataBase?
SpecsApproved?
Tests In
DataBase?
VendorsIn DataBase?
Update DataBase
No
No
No
Yes
No
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Process FlowMaterial Management
Receipt atWarehouse Record into
InventoryReleased
Quarantine,Test &
Release
No
Available for Billof Materials &
ProductionYes
QualityManagerFacility
Manager
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Process Flow - Production
MasterProduction
Bill ofMaterials
ManufacturingInstructions
BatchProduction
ApproveBatch Record
QualityManager
FacilityManager
In ProcessTests
Equipment
Sponsor
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Quick Facts
Developed by the manufacturing andquality experts at PharmaDirections
Integrated internet based application
developed through Quality by Designapproach.
20 Core Standard Operating Proceduresbuilt in
21 CFR Part 11 Compliant
Product has been in use since 2004
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InstantGMPPharmaceutical Contract Manufacturing with a view
Suite of virtual GMP manufacturing systems Takes full advantage of cloud-based computing 21 CFR Part 11 compliant database with hard coded SOP
requirements
Streamlines entire process of producing clinical trialmaterials
Simplifies the documentation and approval procedures toreduce production lead times
Ideally suited to the global market place - manufacturingcan be done in any geographical region while all data
and intellectual property is securely stored in US basedservers
For more information, contact:[email protected]