for IND and RDRC Regulated PET Compounding

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1 Overview of USP Chapter <823> for IND and RDRC Regulated PET Compounding Distributed Manufacturing of PET Radiopharmaceuticals for Multi-Center Clinical Trials SNM, Annual Meeting Toronto, Ontario, Canada June 14, 2009 Sally W. Schwarz, MS, BCNP Director Clinical PET Radiopharmaceutical Production Washington University St. Louis Department of Radiology

2 US Food & Drug Administration Modernization Act (FDAMA) : US Food & Drug Modernization Act (FDAMA) required revisions to Current Good Manufacturing Practice (cgmp) for PET Rdi Radiopharmaceutical i l(rp) production FDAMA required a new approval path and separate Current Good Manufacturing Practices (cgmps) for PET from cgmps for drugs Prior to adoption of final PET cgmp rule, FDAMA requires PET Radiopharmaceutical (RP) production to follow: United States Pharmacopeia (USP) PET RP monographs, if available USP General Chapter <823> for Production of fpet RPs USP subcommittee being formed to review 2005: PET CGMP Proposed Rule & Guidance published 2009: Still waiting for final rule

3 Proposed Rule cgmp for PET September 20, 2005 The proposed 212.5(b) provides that for investigational and research PET drugs, cgmp would be met by producing PET drugs in accordance with USP General Chapter <823> Radiopharmaceuticals for Positron Emission Tomography Compounding. PET Drugs produced under Investigational New Drug Application (IND) (this would apply to Phase 1 and 2) or PET Drugs approved through a Radioactive Drug Research Committee (RDRC)

4 Overview USP Chapter <823> Procedures/Process (Current Chapter 823; revision is planned) Components, Materials and Supplies Written Procedures Acceptance Criteria Compounding Computers & Automated Equipment Verification (3 consecutive runs) & Stability Facilities i Quality Control Sterilization & Sterility Assurance

5 Control of Components, Materials and Supplies Establish written specifications Identity, purity & quality of components Appropriate storage Log-in each lot of shipments of components; If no expiration date, must assign one. Determine each batch of components in compliance with written specifications c s (procedures, es, tests, s, and/or certificates of analysis) Store components in controlled access area according to established conditions.

6 Compounding Procedure Verification 1. Written acceptance criteria for identity, purity & quality of each PET drug (If USP monograph exists = minimum acceptance criteria) 2. Written procedures for compounding Master file of Written compounding procedures (Outdated copies retained) Incorporate 0.22 um for parenteral administration; 0.45 um for inhalation i Routinely updated at least annually 3. Verification Studies Three consecutive runs are required initially & for any change having potential to alter identity quality or purity Stability testing and expiration dating meet acceptance criteria at expiry

7 PET Radiopharamceutical (RPh) Compounding Process Inspect compounding area and equipment before use for cleanliness Label final PET RaPh container prior to starting PET drug name and lot number Compound PET RaPh according to written, verified procedure with appropriate written batch record Use appropriate components Responsible individual initials including including each critical step Raw analytical data Signature & date of individual assuming overall responsibility

8 FDA Audit Inspectional Observations (FDA-483) Failure to audit procedures (SOPs) on regular basis & update Failure to investigate failed batch & deviations (should be in writing) Failure to train personnel to perform assigned tasks Found production equipment: Not qualified Not calibrated Not properly maintained i

9 Quality Control Procedures Written QC procedures Verification of QC equipment and procedures used System suitability ty testing must be confirmed on installation of QC equipment and after repair HPLC, GC, analytic instruments Check correct operation on scheduled basis Maintenance performed written scheduled basis Dose Calibrators: Assay bulk radioactivity and dispensed dosages Perform applicable tests

10 Pre-Release: PET RaPh Quality Control Requirements T 1/2 20 minutes (on Batch); T 1/2 <20 minutes ( on QC Sub Batch) Post-filtration integrity test of 0.22 µm sterile filter (e.g. Bubble Test) ph Visual inspection Radiochemical purity /identity *** Radionuclidic identity Specific activity Residual solvent analysis, and other toxic chemicals BET (20 min gel clot, or other recognized procedure) Post-Release: Sterility may inoculate test, within 24 h following preparation

Endosafe PTS System PTS is a software-driven

analysis of sample and positive control.

11 Endosafe PTS System PTS is a software-driven spectrophotometer for measuring and documenting endotoxin. Unique cartridge containing dry, precalibrated reagents. Each cartridge contains duplicate channels for analysis of sample and positive control. PTS is particularly suited for PET RaPh because test requires ~17-20 minutes Requires < 0.1 ml of diluted product NO preparation of endotoxin standards.

12 FDA Audit Inspectional Observations (FDA-483) Lack of assurance that QC test results are reliable & accurate QC equipment; Not qualified Not calibrated Not maintained No equipment suitability performed (USP Chapter <621>) Inadequate reference standards used Inadequate QA/QC oversight Failure to investigate failed batch Failure to update procedures

13 Qualification of Filtration Process Sterile Filters: COC (certificate of quality) examined and maintained for each lot of filters COA obtained from the company listing microbial retention challenge Each lot of filters must be tested for integrity : Acceptance Criteria After PET drug production, filter tested for integrity ypre- release e.g. Bubble Point Test The bubble point pressure is the pressure at which bubbles first appear from a submerged inlet tube in the receiving vessel. Nitrogen gas flow increased until a streambubbles appear (e.g. most filters must reach > 50 psi. * Nitrogen Gas * Pressure depends on the filter used

14 Facility Environmental Controls Work area is clean Aseptic hood located in low traffic area Clean laboratory clothing worn Aseptic techniques used Disinfect final product septum with sterile 70% alcohol

15 Aseptic Technique Training Requirements Didactic training: pass written exam Training in proper p garbing g& gloving gwith documented visual observation audits Media-Fill Test Procedures New preparer: Pass 3 separate Media-Fill Procedures Annually for personnel who currently prepare (compound) PET RaPh

16 PET RaPh Final Product Vial Assembly Performed In Aseptic Hood PET RaPh final product containers must be assembled in Class 100 environment (LFH or Isolator) Gloved hands are disinfected before entering hood Daily disinfection of surfaces before use Microbiological Testing periodically e.g. weekly (per FDA, NOT monitoring) Contact plate-surfaces Settle plate/dynamic air sampler Airborne, nonviable particle count less often

17 FDA Audit Inspectional Observations (FDA-483) Frequencyq yof environmental monitoring contact plates, touch plates Weekly is not acceptable Should monitor environment for each set-up of final product vial Can assemble all final product vials for the day, and keep them in LAF Use of non-sterile disinfectant to sanitize LAF No media fill testing performed

18 Microbiological Testing of Finished Product Innoculated no later than 24 hours after compounding If sterility test fails, an investigation must be initiated i i to identify if the cause

19 FDA Audit Inspectional Observations (FDA-483) Lack of assurance that PET drug is sterile No growth promotion testing of media performed Must have validation data for hold time (eg. 24 hours); assure still have viable product Inadequate incubation temperature control Automatic sterility re-test without investigation

20 Class 100 (ISO Class 5) PET Dose Drawing Station Chapter <823> supersedes Chapter <797> for PET RP compounding, but upon release of PET RP as finished drug product, further manipulation such as dispensing, contents of Chapter <797> apply. PET Dose Drawing Device In Class 100 Environment Shielded Dose Calibrator

21 Thank-you!

USP Chapter 823 USP 32 (old) vs. USP 35 (new)

USP Chapter 823 USP 32 (old) vs. USP 35 (new) Sally W. Schwarz, MS, BCNP Research Associate Professor of Radiology Washington University School of Medicine St. Louis, MO Why USP Chapter ? FDA has