Working document QAS/13.521/Rev.3 August 2014 Document for comment 1 2 3 4 5 GENERAL GUIDANCE 6 ON “HOLD-TIME” STUDIES 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 REVISED DRAFT FOR COMMENT (August 2014) Should you have any comments on the attached text, please send these to Dr Sabine Kopp, Group Lead, Medicines Quality Assurance, Technologies, Standards and Norms, World Health Organization, 1211 Geneva 27, Switzerland; email: [email protected]; fax: (+41 22) 791 4730 ([email protected]) and to Ms Marie Gaspard ([email protected]), by 30 September 2014. Working documents are sent out electronically and they will also be placed on the Medicines web site for comment. 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Working document QAS/13.521/Rev.3 page 2 47 48 SCHEDULE FOR THE ADOPTION PROCESS OF DOCUMENT QAS/13.521 GENERAL GUIDANCE ON “HOLD-TIME” STUDIES 49 Date Preparation of draft by Dr A.J. van Zyl, South Africa, based on need identified by the WHO Prequalification Programme inspectors November-December 2012 Preliminary internal review of draft January 2013 Draft mailed for comments February 2013 Collation of comments April 2013 Review by inspectors collaborating with the May 2013 WHO Prequalification Programme Discussion during the joint informal consultation with Prequalification Inspection team and inspectors from national inspectorates 30 May 2013 Follow-up of e-Discussion of Subgroup with expert inspectors to finalize new draft of working document for comments June 2013 Recirculation of working document for comments July 2013 Compilation of comments and feedback September 2013 Review of feedback received with Prequalification Inspection team September 2013 Presentation to forty-eighth meeting of the 14-18 October 2013 WHO Expert Committee on Specifications for Pharmaceutical Preparations Review of comments with subgroup of WHO Expert Committee on Specifications for Pharmaceutical Preparations and subsequently with Dr A.J. van Zyl and the Prequalification Team – Inspections Group October 2013–January 2014 Working document QAS/13.521/Rev.3 page 3 Further follow-up action as required … Recirculation of working document for comments February 2014 Compilation of comments April 2014 Discussion of feedback during informal consultation on medicines quality: GXPs, inspection guides and risk management 28-30 April 2014 Recirculation of updated working document August 2014 Compilation of comments and evaluation of End September 2014 feedback received 50 51 Presentation to forty-ninth meeting of the WHO Expert Committee on Specifications for Pharmaceutical Preparations October 2014 Further follow-up action as required … Working document QAS/13.521/Rev.3 page 4 52 GENERAL GUIDANCE ON “HOLD-TIME” STUDIES 53 54 CONTENTS 55 56 1. INTRODUCTION AND BACKGROUND 57 2. GLOSSARY 58 3. SCOPE 59 4. ASPECTS TO BE CONSIDERED 60 61 62 63 64 1. INTRODUCTION AND BACKGROUND 65 66 Manufacturers should ensure that the products that they manufacture are safe, effective 67 and of the quality required for their intended use. Products should be consistently 68 manufactured to the quality standards appropriate to their intended use and as required by 69 the marketing authorization. Systems should ensure that pharmaceutical products are 70 produced according to validated processes and to defined procedures. Manufacturing 71 processes should be shown to be capable of consistently manufacturing pharmaceutical 72 products of the required quality that comply with their specifications. 73 74 Arrangements should exist to ensure that the dispensed raw materials and packaging 75 materials, intermediate products, bulk and finished products are stored under appropriate 76 conditions. Storage should not have any significant negative effect on the processing, 77 stability, safety, efficacy or quality of the materials, intermediate products and bulk 78 products prior to final packing. Good manufacturing practices (GMP) require that a 79 maximum acceptable holding period should be established to ensure that intermediates 80 and bulk product can be held, pending the next processing step, without any significant Working document QAS/13.521/Rev.3 page 5 81 adverse effect to the quality of the material. Such a holding period should be underwritten 82 by data, but need not be extended to find the edge of failure. 83 84 2. GLOSSARY 85 86 Bulk product 87 Any pharmaceutical product which has completed all processing stages up to, but not 88 including, final packaging. 89 90 Intermediate 91 Partly processed product that must undergo further manufacturing steps before it becomes 92 a bulk product. 93 94 3. SCOPE 95 96 This guideline focus primarily on aspects that should be considered in the design of the 97 hold-time studies during the manufacture of solid dosage forms. Many of the principles 98 herein also apply to other dosage forms such as liquids, creams and ointments. This 99 guideline does not cover aspects for hold times in cleaning validation or the 100 manufacturing of active pharmaceutical ingredients (APIs). 101 102 This guideline is intended as a basic guide for use by pharmaceutical manufacturers and 103 GMP inspectors. This document does not intend to prescribe a process for establishing 104 hold times, but reflects aspects that should be considered in the design of the hold-time 105 study. 106 107 Manufacturers should gather scientific and justifiable data to demonstrate that the 108 dispensed raw materials and packaging materials, intermediate and bulk products: 109 110 - remain of appropriate quality before processing to the next stage; Working document QAS/13.521/Rev.3 page 6 111 - meet the acceptance criteria and release specification for the finished product. 112 113 4. ASPECTS TO BE CONSIDERED 114 115 Hold time can be considered as the established time period for which materials 116 (dispensed raw materials, intermediates and bulk dosage form awaiting final packaging) 117 may be held under specified conditions and will remain within the defined specifications. 118 119 Data to justify the hold time can be collected, but not limited to: 120 - during development on pilot-scale batches, 121 - during scale up, 122 - during process validation, or 123 - as part of an investigation of a deviation that occurred during manufacture. 124 Hold-time studies establish the time limits for holding the materials at different stages of 125 production to ensure that the quality of the product does not deteriorate significantly 126 during the hold time. The design of the study should reflect the holding time at each 127 stage. Hold times should normally be determined prior to marketing of a product and 128 following any significant changes in processes, equipment, starting and packaging 129 materials and represent actual processing. Hold time studies should be included during 130 process validation (Ref: Process validation guideline). 131 132 Manufacturers may use a flow chart to review the manufacturing procedure of a product 133 and then break up the critical stages of manufacturing process on the basis of time 134 duration required for the particular storage and processing stages, typical pauses in the 135 manufacturing campaign, and the potential impact of storage with reference to 136 environmental and storage conditions. An example for a flow chart is given below. 137 138 For example, for oral tablets that are coated the following stages may be considered: 139 140 - binder preparation to granulation – consider the granulate; Working document QAS/13.521/Rev.3 page 7 141 - wet granulation to drying – the dried granulate; 142 - dried granules to lubrication/blending – the lubricated blend; 143 - blend to compression; 144 - compression to coating – the tablet cores; 145 - coating solution to preparation – the coating solution; 146 - coating to packing – consider the bulk coated tablets; 147 - coating to packing in bulk or FDF; 148 - packing in bulk to FDF. 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 Example for a flow chart : Dispensing Sifting Dry Mixing Granules: Sample withdrawn for analysis Granulation Binder Sample withdrawn for analysis Drying Lubrication &Blending Blend: Sample withdrawn for analysis Core tablets: Sample withdrawn for analysis Compression Coated tablet: Sample withdrawn for analysis Coating Packing Drying Coating Solution: Sample withdrawn for analysis Working document QAS/13.521/Rev.3 page 8 181 182 A written protocol, procedure or programme should be followed which includes the 183 activities to be performed, test parameters and acceptance criteria appropriate to the 184 material or product under test. The protocol and report should generally include the 185 following: a title; reference number; version; date; objective; scope; responsibility; 186 procedure; description of the material/product; sample quantities; sampling method and 187 criteria; acceptance limits; frequency for sampling; sampling locations; pooling of 188 samples; storage conditions; type of container; methods of analysis; results; conclusion; 189 recommendation; signatures and dates. Acceptance criteria are typically more stringent 190 than registered specifications to provide assurance that the material is well within control. 191 When setting the specifications any known stability trends will need to be taken into 192 account. 193 194 For certain products microbiological aspects should also be considered and included 195 where appropriate. 196 197 Typically one or more batches of a material, intermediate or product can be used for 198 determining hold times. A risk-based approach can be used to determine the appropriate 199 number of batches, considering inter alia the characteristics of the materials A 200 representative sample of the batch of material or product subjected to the hold-time study 201 should be held for the defined hold period. The maximum hold period for each category 202 of material should be established on the basis of the study by keeping the material in 203 either the original or simulated container used in production. The containers used in 204 which hold-time samples are stored should be the same pack as used in production unless 205 the pack is exceptionally large, in which case one that is equivalent (same material of 206 construction and closure system to the production packaging system) may be used. 207 Reducing the size of container when necessary for testing holding time, should be 208 justified. Where head space is important the hold-time samples should represent the 209 maximum 210 manufacturing/quarantine. The sample storage environmental conditions should be same 211 as that of the quarantine area/manufacture stage.Asampling plan should be established possible head space (worst-case scenario) to bulk stored in Working document QAS/13.521/Rev.3 page 9 212 and followed for taking samples for testing at the different intervals. The required sample 213 amount should be calculated based on the batch size, the intervals and tests to be 214 performed. Results should be compared with the initial baseline data of the control 215 sample . Samples may be pooled for analysis where appropriate, e.g. when the analysis of 216 a composite sample will not miss issues expected in the variation of the product. 217 218 Where appropriate, statistical analysis of the data generated should be performed to 219 identify trends and to justify the limits and hold time set. 220 221 Batches of finished products made from intermediates or bulk products and subjected to a 222 hold-time study should be considered for long-term stability testing if data show adverse 223 trending or shifting patterns during the intermediate time points up to the end of the 224 shelf-life. The shelf-life of the product – irrespective of hold times – should be measured 225 from the time the active ingredients are mixed with other ingredients. Normally 226 intermediate and bulk products should not be stored beyond the established hold time. All 227 testing of bulk intermediates and product should be performed using validated stability- 228 indicating methods. 229 230 The following table provides examples of stages and tests that may be considered. 231 232 Table: Examples of stages and tests that may be considered, based on risk assessment 233 and specific product needs Stage Test to be carried out as per specification Study time Binder preparation Microbial test Initial, 2hrs, 5hrs, 8hrs. In case of starch: initial, 2hrs, 5hrs Solution prepared (including granulation pastes, coating solution and coating suspensión Physical appearance, Specific gravity, Viscosity, Sedimentation, pH, Microbial test Initial, 12, 24, 36, 48, 60, 72 hours Working document QAS/13.521/Rev.3 page 10 Granule Description, Assay, Related substances, Loss on drying, Water content, Particle size distribution, Bulk density, Tap density, Angle of repose. Initial, 30th day, 45th day Blend Microbial test, Loss on drying, Blend uniformity, Particle size, Bulk/Tapped density Initial, 30th day, 45th day Core tablets – uncoated (in bulk container Description, Hardness, Thickness, Friability, Disintegration, Dissolution or Dissolution profile, assay, Degradation products/ related substance, Uniformity of dosage units, Microbial test. Description, Hardness, Thickness, Friability, Disintegration, Dissolution or Dissolution profile, Assay, Degradation products/ related substance, Uniformity of dosage units , Moisture content, Microbial test. Initial, 30th day, 60th day & 90th day Coated tablets (in bulk container) 234 235 236 *** Initial, 30th day, 60th day & 90th day
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