WHO Training Workshop on Pharmaceutical Quality, GMP and Bioequivalence with a focus on artemisinines
STABILITY STUDIES Assessment experience
Jnos Pogny, pharmacist, Ph.D. consultant to WHO Guilin, China, 9 January 2006 E-mail:
[email protected]2006.01.09. Dr. Pogny - Guilin
1/61
Abbreviations
API EoI FDC FPP GMP ICH MA DRA Active Pharmaceutical Ingredient Expression of Interest Fixed-Dose Combination Finished Pharmaceutical Product Good Manufacturing Practices International Conference on Harmonization Marketing Authorization Drug Regulatory Authority
Green WHO Blue ICH
Yellow emphasis
2006.01.09.
Dr. Pogny - Guilin
2/61
Applicable guidelines
WHO Guidelines for stability testing of pharmaceutical products containing well established drug substances in conventional dosage forms WHO working document QAS/05.146 - Stability Studies in a Global Environment. ICH guidelines Q1A-Q1F. Stability testing of new APIs and FPPs has been harmonized at global level.
2006.01.09. Dr. Pogny - Guilin
3/61
Applicable guidelines
WHO Guideline on Submission of Documentation for Prequalification of Multi-source (Generic) Finished Pharmaceutical Products (FPPs) Used in the Treatment of HIV/AIDS, Malaria and Tuberculosis. Annex 4. Stability requirements for variations and changes to prequalified FPPs (draft) Supplement 2 [for use from July 2005 (CPH25)] Extension of the WHO List of Stable (not easily degradable ARV) APIs. Further potential APIs are e.g., amodiaquine, mefloquine, and so on.
2006.01.09. Dr. Pogny - Guilin
4/61
Subjects for Discussion
1.
2. 3.
Essential ICH definitions
Interchangeability of FPPs Planning stability studies and reporting results
4.
5. 6. 7.
Stability testing of APIs
Stability testing of FPPs Evaluation of stability results Main points again
2006.01.09. Dr. Pogny - Guilin
5/61
STABILITY STUDIES
ESSENTIAL ICH DEFINITIONS
Selected definitions
Re-test date
The date after which samples of an API should be examined to ensure that the material is still in compliance with the specification and thus suitable for use in the manufacture of a given FPP.
Shelf life (expiration dating period, conformance period)
The time period during which an API or a FPP is expected to remain within the approved shelf-life specification, provided that it is stored under the conditions defined on the container label. See also Notes Page
2006.01.09. Dr. Pogny - Guilin
7/61
Selected definitions
Formal stability studies Long term and accelerated (and intermediate) studies undertaken on primary and/or commitment batches according to a prescribed stability protocol to establish or confirm the re-test period of an API or the shelf life of a FPP. Stress testing forced degradation (API) Studies undertaken to elucidate the intrinsic stability of the API. Such testing is part of the development strategy and is normally carried out under more severe conditions than those used for accelerated testing. Stress testing forced degradation (FPP) Studies undertaken to assess the effect of severe conditions on the FPP. Such studies include photostability testing (see ICH Q1B) and compatibility testing on APIs with each other in FDCs and API(s) with excipients during formulation development. See also Notes Page
2006.01.09.
Dr. Pogny - Guilin
8/61
Selected definitions
Primary batch
A batch of an API or FPP used in a formal stability study, from which stability data are submitted in a registration application for the purpose of establishing a re-test period or shelf life, respectively. A primary batch of an API should be at least a pilot scale batch. For a FPP, two of the three batches should be at least pilot scale batch, and the third batch a production batch.
Commitment batches
Production batches of a drug substance or drug product for which the stability studies are initiated or completed post approval through a commitment made in the registration application. See also Notes Page
2006.01.09.
Dr. Pogny - Guilin
9/61
Selected definitions
Pilot (scale) batch
A batch of an API or FPP manufactured by a procedure fully representative of and simulating that to be applied to a full production scale batch. (For solid oral dosage forms, a pilot
scale is generally, at a minimum, one-tenth that of a full production scale or 100,000 tablets or capsules, whichever is the larger.)
Production (scale) batch
A batch of an API or FPP manufactured at production scale by using production equipment in a production facility as specified in the application.
2006.01.09.
Dr. Pogny - Guilin
10/61
Selected definitions
Supporting data
Data, other than those from formal stability studies, that support the analytical procedures, the proposed re-test period or shelf life, and the label storage statements. Such data include (1) stability data on early synthetic route batches of API, small-scale batches of materials, investigational formulations not proposed for marketing, related formulations, and product presented in containers and closures other than those proposed for marketing; (2) information regarding test results on containers; and (3) other scientific rationales.
2006.01.09.
Dr. Pogny - Guilin
11/61
Selected definitions
Specification - Release
The combination of physical, chemical, biological, and microbiological tests and acceptance criteria that determine the suitability of a drug product at the time of its release.
Specification - Shelf life
The combination of physical, chemical, biological, and microbiological tests and acceptance criteria that determine the suitability of an API throughout its re-test period, or that anFPP should meet throughout its shelf life. See also Notes Page
Mass balance
The process of adding together the assay value and levels of degradation products to see how closely these add up to 100% of the initial value, with due consideration of the margin of analytical error.
2006.01.09. Dr. Pogny - Guilin
12/61
INTERCHANGEABILITY
STABILITY EQUIVALENCE
Interchangeability (IC)
Interchangeability (IC) of multisource FPPs =
(Essential similarity with innovator FPP) =
Pharmaceutical equivalence (PE) +
Bioequivalence (BE)
IC = PE + BE
2006.01.09. Dr. Pogny - Guilin
14/61
Pharmaceutical equivalence
FPPs meet same or comparable standards
(pharmacopoeia, marketing authorization)
Same API (chemical and physical equivalence) Same dosage form and route of administration Same strength Comparable labeling WHO-GMP (batch-to-batch uniformity of quality) STABILITY EQUIVALENCE
2006.01.09.
Dr. Pogny - Guilin
15/61
High-risk APIs and FPPs
Reference standard/comparator is not available for:
Pharmaceutical (stability) equivalence studies Bioequivalence studies
APIs and FPPs are not official in the internationally used major pharmacopoeias WHO guides/SOPs apply to multisource FPPs. ICH guides should be used for evaluation. Require particular attention by national DRA as regards assessment of applications for marketing authorization
2006.01.09.
Dr. Pogny - Guilin
16/61
Low-risk APIs
1. Certificate of suitability (DRA)
2. Drug Master File
Open part (APPLICANT) Closed part (DRA) Literature evidence of stability Synthesis impurities are controlled by monograph (toxicology of additional impurities) Class1 solvents excluded, class2 solvents controlled
3. Pharmacopeia monograph
4. FPP is registered in the ICH region
2006.01.09. Dr. Pogny - Guilin
17/61
Planning stability studies and reporting results
Annex 3: Model Stability Protocol and Report of API
Stability Protocol and Report
Batches tested General information Container/closure system Literature and supporting data Stability-indicating analytical methods Testing plan Test parameters Test results Other requirements (post-approval commitments) Conclusions Result sheets must bear date and responsible person signature / QA approval
1. 2. 3. 4. 5. 6. 7. 8. 9. 10.
2006.01.09. Dr. Pogny - Guilin
19/61
Illustrative data of API stability batches
Batch number Date of manufacture
Site of manufacture Batch size (kg) Primary packing materials Date of initial analysis
The batches should be representative of the manufacturing process and should be manufactured from different batches of key intermediates.
2006.01.09. Dr. Pogny - Guilin
20/61
Illustrative data of capsule/tablet stability batches
Batch number Date of manufacture Site of manufacture Batch size (kg) Batch size (number of units) Primary packing materials Date of initial analysis Batch number of the API
The batches should be representative of the manufacturing process and should be manufactured from different batches of APIs.
2006.01.09. Dr. Pogny - Guilin
21/61
2.7 Stability Testing - API
2.7.1 Stress testing (forced degradation) 2.7.2 Regulatory stability testing
ICH guidelines on stress testing
Standard Title and reference
Products (the parent guideline)
ICH Q1A(R2) Stability Testing of New Drug Substances and ICH Q1B ICH Q2B ICH Q3A(R) ICH Q3B(R)
2006.01.09.
Photostability Testing of New Drug Substances and Products Validation of Analytical Procedures: Methodology Impurities in New Drug Substances Impurities in New Drug Products
Dr. Pogny - Guilin
23/61
Forced degradation tests
To identify potential degradants (degradation pathways) of the API and assess if they can be formed during manufacture or storage of the FPP (intrinsic stability of the API). To validate the stability indicating power of the analytical procedures. To identify stability-affecting factors such as ambient temperature, humidity and light and to select packing materials, which protect the FPP against such effects. No standard method for testing. See also Notes Page
2006.01.09. Dr. Pogny - Guilin
24/61
Prequalification experience
Results Deceptive Predictive Comments Degradation level is good (<15%) but no relevant degradants are observed Degradation level is good (<15%) and at least one or all relevant degradants are observed Between 15 and 100% degradation but no relevant degradants observed
Dr. Pogny - Guilin
Useless
2006.01.09.
25/61
Requirements for predictive stress conditions
Recommendations in Supplement 2: Should lead to the degradation of the main compound, but not more than 5-15%. Should lead to a good predictability of degradation pathways (i.e., a low probability of "drastic" or "false" degradation) Should be conducted for no longer than three months.
2006.01.09.
Dr. Pogny - Guilin
26/61
Stress testing of API in solution
Storage conditions
pH 2, room temperature
pH 7, room temperature pH 10-12, room temperature
Testing period*
2 weeks
2 weeks 2 weeks
H2O2, 0.1-2% at neutral pH, room temperature
24 hours
* Storage times given or 5-15% degradation, whatever comes first See also Notes Page
2006.01.09. Dr. Pogny - Guilin
27/61
Regulatory or formal stability testing
Storage temperature (C)
Relative humidity (%) 755
655 605
Accelerated: 402
Intermediate: 302 Long term: 252
Minimum time period covered by data at submission (months) 6
12 12 (6)
2006.01.09.
Dr. Pogny - Guilin
28/61
Stability Room
1. A special cabinet for each condition
2. Design, construction, qualification, monitoring 3. Costs of operation including R + D failures 4. Time
5. Do we need new standard conditions?
2006.01.09. Dr. Pogny - Guilin
29/61
Stability results
A storage statement should be proposed for the labeling (if applicable), which should be based on the stability evaluation of the API. A re-test period should be derived from the stability information, and the approved retest date should be displayed on the container label.
An API is considered as stable if it is within the defined/regulatory specifications when stored at 302oC and 655% RH for 2 years and at 402oC and 755%RH for 6 months.
2006.01.09.
Dr. Pogny - Guilin
30/61
3.11 Stability testing - FPP
Regulatory stability testing Stress testing (forced degradation)
Potential instability issues of FPPs
Loss/increase in concentration of API
Formation of (toxic) degradation products Modification of any attribute of functional relevance Alteration of dissolution time/profile or bioavailability Decline of microbiological status Loss of package integrity Reduction of label quality Loss of pharmaceutical elegance and patient acceptability
2006.01.09.
Dr. Pogny - Guilin
32/61
3.11.1 Stability-indicating quality parameters
Stability studies should include testing of those attributes of the FPP that are susceptible to change during storage and are likely to influence quality, safety and/or efficacy. For instance, in case of tablets:
appearance friability dissolution time assay hardness moisture content degradants microbial purity
2006.01.09.
Dr. Pogny - Guilin
33/61
Increase in concentration of API
During stability studies of Artesunate, the assay results were increasing. The hydrolysis may yield artenimol and succinic acid. The latter can justify the increase in assay. The assay method is stability indicating but not specific.
2006.01.09.
Dr. Pogny - Guilin
34/61
3.11.3 Selection of Batches
At the time of submission data from stability studies should be provided for batches of the same formulation and dosage form in the container closure system proposed for marketing. Stability data on three primary batches are to be provided. The composition, batch size, batch number and manufacturing date of each of the stability batches should be documented and the certificate of analysis at batch release should be attached. Where possible, batches of the FPP should be manufactured by using different batches of the API.
2006.01.09.
Dr. Pogny - Guilin
35/61
Significant Change of FPPs
A 5% change in assay from its initial value. Any degradation product exceeding its acceptance criterion. Failure to meet the acceptance criteria for appearance, physical attributes, and functionality test (e.g., color, phase separation, hardness). As appropriate for the dosage form, e.g., failure to meet the acceptance criteria for dissolution for 12 dosage units.
2006.01.09. Dr. Pogny - Guilin
36/61
Pitfall
The assay value is still within the limits but the change during stability is more than 5.0% Example
Release assay limit: 95.0 105.0% Stability assay limit: 92.5 105.0% Release assay: 101.0% (within spec) 24-Month assay: 93.0% (within spec) Loss in potency: 8.0%. This is a significant change.
2006.01.09.
Dr. Pogny - Guilin
37/61
2.2.3 Tests at elevated temperature and/or extremes of humidity (ICH-Q1F)
Special transportation and climatic conditions outside the storage conditions recommended in this guideline should be supported by additional data. For example, these data can be obtained from studies on one batch of drug product conducted for up to 3 months at 50C/ambient humidity to cover extremely hot and dry conditions and at 25C/80% RH to cover extremely high humidity conditions. Stability testing at a high humidity condition, e.g., 25C/80% RH, is recommended for solid dosage forms in water-vapour permeable packaging, e.g., tablets in PVC/aluminum blisters, intended to be marketed in territories with extremely high humidity conditions in Zone IV. However, for solid dosage forms in primary containers designed to provide a barrier to water vapour, e.g. aluminum/aluminum blisters, stability testing at a storage condition of extremely high humidity is not considered necessary.
2006.01.09.
Dr. Pogny - Guilin
38/61
Stress testing of FPPs in solid state
Storage conditions
40C, 75 % RH; open storage** 50-60 C, ambient RH; open storage Photostability; according to ICH
Testing period*
3 months 3 months according to ICH
* 3 months or 5-15% degradation, whatever comes first ** For API1-API2, or API-excipient, or FPP without packing material, typically a thin layer of material is spread in a Petri dish. Open storage is recommended, if possible.
2006.01.09. Dr. Pogny - Guilin
39/61
Stability studies API and FPP
Evaluation of results
3.11.10 Evaluation
A systematic approach should be adopted in the presentation and evaluation of the stability information. Where the data show so little degradation and so little variability that it is apparent from looking at the data that the requested shelf life will be granted, it is normally unnecessary to go through the formal statistical analysis; providing a justification for the omission should be sufficient. An approach for analysing data on a quantitative attribute that is expected to change with time is to determine the time at which the 95% one-sided confidence limit for the mean curve intersects the (lower) acceptance criterion (95% assay).
2006.01.09.
Dr. Pogny - Guilin
41/61
Evaluation Best Case
1. Tabulate and plot stability data on all attributes at all storage conditions and evaluate each attribute separately. 2. No significant change at accelerated conditions within six (6) months. 3. Long-term data show little or no variability and little or no change over time.
2006.01.09.
Dr. Pogny - Guilin
42/61
Evaluation Best Case
4. Accelerated data show little or no variability and little or no change over time. 5. Statistical analysis is normally unnecessary. 6. Proposed retest period or shelf life = double of period covered by long-tem data (X) but NMT X + 12 months 7. A retest period or shelf life granted on the basis of extrapolation should always be verified by additional long-term stability data
2006.01.09. Dr. Pogny - Guilin
43/61
Visible variability and trend
1. Is there "little or no data
variability"?
(High variability without
change over time suggests potential problem with accuracy/precision of analytical method.)
2. Is there "little or no change-
over-time" in stability data?
2006.01.09. Dr. Pogny - Guilin
44/61
Visible variability and trend
The simple linear regression analysis yields the equation: Y = slope X + intercept where Y is the assay, X is the time factor expressed in months, the slope is the degradation rate and the intercept is the assay at time = 0. Regression analysis provides two additional factors: the p-value of the slope and the standard deviation about the regression line SX/Y
2006.01.09. Dr. Pogny - Guilin
45/61
Visible variability and trend
The p-value is the smallest level of significance that would lead to rejection of the null hypothesis. (The ICH Q1A states p = 0.25 for accepting the equality
of slopes and zero intercepts of regression lines of different batches. See Notes page )
Variability is taken to be reflected by the spread of data around the previously derived regression line. The standard deviation about the regression line SY/X is a measure of this spread.
2006.01.09. Dr. Pogny - Guilin
46/61
Visible variability and trend
To account for the relative nature of the data
variability, it is suggested here to employ the Capability Index, Cpk, a term borrowed from the field of statistical process control. The capability of a process is defined as 6, which is the range where 99.7% of the measurements lie (assuming a normal distribution).
2006.01.09. Dr. Pogny - Guilin
47/61
Process capability index, Cp
acceptance limits
Cp = process capability =
UCL - LCL
6*
* ... is the measured standard deviation of the process
acceptance limits Cpk =
UCL - LCL =
process capability
6 SY/X
2006.01.09.
Dr. Pogny - Guilin
48/61
Visible variability and trend
Perform linear regression analysis on either accelerated or long-term stability data
p > 0.25. Yes. There is little or no a change-over-time Cpk > 2.5. Yes. There is little or no data variability
2006.01.09.
Dr. Pogny - Guilin
49/61
ICH-Q1E Evaluation for Stability Data
2006.01.09.
Dr. Pogny - Guilin
50/61
Evaluation Change with Time
The hypothetical figure in the former slide illustrates that the extrapolated shelf life is 29 months (25oC/60%RH) and there is only a 5% chance that this estimate will be high. Such a plot covers assay values from 100% down to 95%. The majority of degradation processes results in an essentially linear line in this range of the label claim thus the method is generally applicable for the estimation of the expiry date at the studied storage conditions.
2006.01.09. Dr. Pogny - Guilin
51/61
Carstensen, J.T. Drug stability
2006.01.09.
Dr. Pogny - Guilin
52/61
Evaluation Change with Time*
The hypothetical figure in the former slide illustrates that the shelf life is 24 months (at a given temperature). There is a 5% chance that this estimate will be high. Such a plot covers potency values from 100% down to 90%.
* DRUG STABILITY Principles and Practices
Edited by Jens T. Carstensen and C. T. Rhodes Third edition, revised and expanded (2000) Marcel Dekker, Inc., 270 Madison Avenue, New York,
2006.01.09.
Dr. Pogny - Guilin
53/61
ICH-Q1E Evaluation for Stability Data
2006.01.09.
Dr. Pogny - Guilin
54/61
Evaluation Change with Time
The hypothetical figures in the former slides illustrate that the shelf life is 31-32 months (25oC/60%RH) and there is only a 5% chance that this estimate will be high. Such a plot covers degradant values from 0.6% up to 1.4%. For FPPs in semipermeable containers, loss of vehicle can result in an increase in the API concentration. In such cases, the point where the upper 95% confidence bound intersects the 105% assay value will define the conformance period.
2006.01.09. Dr. Pogny - Guilin
55/61
Release and shelf-life specifications
It may be appropriate to have justifiable differences between the shelf life and release acceptance criteria based on the stability evaluation and the changes observed on storage. Shelf-life acceptance criteria should be derived from consideration of all available stability information. Release and shelf-life dissolution acceptance criteria (Q and t) must be the same List of approved suppliers.
2006.01.09. Dr. Pogny - Guilin
56/61
Commitment
For confirmation of provisional (tentative) shelf-life, real-time data are required
First 3 production batches on stability Follow up stability testing (FUST) one batch per year
2006.01.09.
Dr. Pogny - Guilin
57/61
Additional or New Stability Data
Variations affecting one or more steps of the
same route of synthesis of an API Change in the route of synthesis of an API Change in composition of the FPP Change in immediate packaging of the FPP
2006.01.09.
Dr. Pogny - Guilin
58/61
Main points again
Stability studies should be planned on the basis of pharmaceutical R+D and regulatory requirements. Forced degradation studies reveal the intrinsic chemical properties of the API, while formal stability studies establish the retest date. The shelf life (expiry date) of FPPs is derived from formal stability studies. Variability and time trends of stability data must be evaluated by the manufacturer in order to propose a retest date or expiry date.
2006.01.09. Dr. Pogny - Guilin
59/61
Key literature references
Drug Stability: Principles and Practices, 3rd Edition, edited by Jens T. Carstensen and C. T. Rhodes (Marcel Dekker, Inc., New York, 2000)
Silke Klick and others: Toward a Generic Approach for
Stress Testing of Drug Substances and Drug Products (Pharmaceutical Technology, February 2005) Raphael Bar: Statistical Evaluation of Stability Data: Criteria for Change-over-time and Data Variability (PDA Journal of Pharmaceutical Science and Technology, Vol. 57. No.5, Sept./Oct. 2003, pp. 369-377)
2006.01.09.
Dr. Pogny - Guilin
60/61
THANK YOU
2006.01.09.
Dr. Pogny - Guilin
61/61
