28DickinsonClinical Relevance of Dissolution

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    Clinical Relevance of DissolutionTesting in Quality by Design

    AAPS workshop on BE, BCS and Beyond, May

    2007, co-sponsored with FDA

    Bertil S. Abrahamsson Ph.D. [email protected]

    Paul A. Dickinson Ph.D. [email protected]

    2

    Outline:

    Introduction to Quality by Design (QbD)

    A driver to go beyond BE and BCS

    Review the current accepted practices for demonstrating clinical quality

    Focus on approaches for BCS2 compounds

    Case study FDA pilot programme

    Evaluation of clinical impact of key product and process variables

    Establishment of the Clinical Boundary of the Design Space

    Potential Regulatory Flexibility and Continuous Improvement

    Generic overview

    Aim:

    Propose to demonstrate how BCS and dissolution testing can be applied toQbD to assure clinical quality

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    Acknowledgments

    PAR&D

    Paul Stott

    Sheena Behn

    Andy Townsend

    Ryan Gibb

    Andy Sheridan

    John Smart

    Chris Potter

    Clin Pharm

    Peter McCormack

    Parvis Ghahramani

    Tracey Hammett

    Reg CMC

    Linda Billett

    Bob Timko

    Carol Stinson

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    AstraZeneca have Adopted a Science and Risk Based

    Approach to Clinical Quality

    ICH Q8

    Design Space

    Multi-dimensional space that encompasses combinations of productdesign, manufacturing process design, critical manufacturing processparameters and component attributes that provide assurance of suitableproduct quality and performance

    ICH Q9

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    Maximally Efficient, Agile and Flexible Manufacturing

    Regulatory Flexibility to Change:

    Site

    Scale

    Process conditions

    Process Type

    Excipient Grade

    Formulation

    Drug Form

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    1

    3

    2

    4

    What are the expectations for demonstrating clinical quality

    (safety and efficacy) today?

    Bioequivalence

    Study.

    Dissolution for someSUPAC changes

    Biowaiver:Dissolution:

    Rapid and complete,

    across the physiological PH

    range

    Bioequivalence

    Study.Dissolution for some

    SUPAC changes

    Bioequivalence

    Study.

    Dissolution for someSUPAC (smaller) changes

    SolubilityHigh Low

    PermeabilityH

    igh

    Low

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    So what does this mean in practice?

    The previous approach to development didnt build knowledge and

    encourage understanding

    Thus was long and risk laden and resource intensive

    Ajax Hussain,

    FDA, 2005

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    (One of ) AZs Response(s) to this initiative

    The next part of the presentation will cover how we have applied a

    SCIENTIFIC and RISK BASED approach to produce a Quality by

    Design Development package for an AZ BCS2 product

    We believe this will meet the desired state as described by Janet

    Woodcock

    This approach has already allowed us to streamline pharmaceutical

    development

    No final BE study

    No clinical PK bridging study between Phases

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    Drug Substance Properties

    Molecular Weight: 475

    pKa: 9.41 and 5.33 (dibasic)

    ClogP : 5.7

    LogD(octanol): 2.6

    displays high permeability

    Low solubility

    Stable in GI Fluid

    has a prolonged absorption rate

    (~Ka 0.33hr-1)

    long half life (~10-15 days)

    BCS Class II

    Amount dissolved in 250 mL (mg)

    1

    10

    100

    1000

    0 1 2 3 4 5 6 7 8 9

    pH

    dissolvedin

    250mL(mg)

    >300mg

    Permeability of Caco-2 Monolayers to Drug Substance (mean sd, n=3)

    Conc (M) Papp (A to B)

    (x 10-6

    cms-1

    )

    Papp (B to A)

    (x 10-6

    cms-1

    )

    B to A :A to B

    Papp ratio

    Absorption

    potential

    Efflux

    1 17.90.9 14.03.3 0.78 High No

    10 23.80.1 17.81.7 0.75 High No

    50 31.21.0 16.82.0 0.54 High No

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    Key High Level Risks for the Drug Product

    Applying a scientific and risk based approach an High Level Quality

    Risk Assessment (QRA) was performed predicated on prior

    knowledge from other projects and specific knowledge about the

    drug substance.

    This identified two high level risks for the drug substance

    1. Impact of product / process variables on in vivo

    performance (BCS Class II)

    2. Compression properties leading to poor physical quality Wet granulated IR tablet

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    Clinical Quality Boundary

    In order to fully understand the Design Space it is important to assess

    the clinical impact of the most relevant process variables and materialattributes

    i.e. the impact of these variables on safety and efficacy

    For a BCS Class II (and III, IV) it is not possible to test all the potential

    tablet variants generated during the establishment of the

    manufacturing design space in the clinic.

    Therefore need to establish a link between an in vitro test (we have

    chosen dissolution) and safety and efficacy (volunteer PK)

    Once this link has been established the dissolution test can be used as

    a surrogate of clinical performance and the clinical performance of all

    variants from the design space establishment can be assessed.

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    Most Relevant Variables for Clinical Quality

    For a BCS Class II compound factors that are most likely to impact on clinicalperformance are those that will retard drug release (dissolution rate)

    A risk analysis, based on prior knowledge of this and other products, wasused to identify the most relevant process parameters and quality attributesthat could affect in vivo dissolution of the product and thereby impact onClinical Quality. These were/are:

    API physical properties (API Design Space) particle size

    Extent of granulation (Process Design Space)

    Level of binder and disintegrant (Formulation Design Space)

    These variables retard drug dissolution by different mechanisms,namely:

    Impact of API surface area on rate of dissolution

    Impact of granule density and porosity on the rate of ingress of water

    Impact of slowed disintegration rate of the tablet on subsequent drugdissolution

    Tablet variants, encompassing the extremes of these variables, weremanufactured with the intention of producing tablets with retardeddissolution rates.

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    Initial Clinical Quality Risk Assessment

    Raw materials and formulation Process

    Highest risks assessed in vivo

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    The four tablet variants were:

    Standard Clinical Manufacture; Large Particle Size Variant;

    Process Variant (Over granulation); Formulation Variant (less

    disintegrant, more binder)

    Tested in vitro to develop dissolution method capable of

    identifying changes in product quality due to changes in these

    most relevant process parameters and quality attributes

    Tested in vivo evaluate impact of these variables on in vivo

    performance and if appropriate develop a mathematical

    relationship (IVIVC)

    Evaluation of most relevant variables

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    Dissolution in pharmacopoeial media demonstrate either a lack of differentiation (pH

    1.2), higher variability (both pH 1.2 and 4.5) or incomplete recovery (pH 6.8) and

    therefore are sub-optimal (when discrimination was observed it was the same rankorder as that seen in the chosen media)

    The most appropriate dissolution method identified discriminates between most

    relevant process parameters and quality attributes in the tablet variants

    Dissolution Method Development

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    Time (minutes)

    %D

    issolution

    Variant A (Standard tablet)

    Variant B (Larger particle size)

    Variant C (Process variant)Variant D (Formulation variant)

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    Geometric Mean and Individual Plasma Concentrations from Tablet Variants

    (n = 10 for Variants A and B, n = 11 for Variant C and n = 9 for Variant D) versus Oral Solution (n = 15)

    after dosing to healthy volunteers

    No difference in PK performance (Cmax and AUC) after dosing the tablet variants to

    volunteers

    i.e. not appropriate to try to develop an IVIVC

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    The in vivo evaluation demonstrated that changes in the most

    relevant Process Parameters and Quality Attributes did not affectPK in volunteers

    i.e. will have no impact on safety and efficacy in patients

    Cannot develop an IVIVC because the PK profiles overlap and

    there are no differences in vivo

    However, the impact of these variables on dissolution when tested

    by the most appropriate method, could be detected

    i.e. over discriminatory method

    As the variants dosed encompassed three different mechanisms to

    alter drug release from the tablet the overly discriminatory

    dissolution test is an appropriate surrogate to assess clinical quality

    of all outputs from further processing studies

    Study Conclusions

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    If product has a dissolution profile faster than that of slowest profiledosed to volunteers (Variant D) then clinical efficacy and safety will

    be comparable to clinical trials material (Clinical Quality Boundary)

    Proposed Design Space for Clinical Quality

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    Implications of clinical evaluation of product & process variables

    This approach defines the clinical boundary of the Design Space for

    the product

    the dissolution method is a suitable surrogate for clinical

    performance

    The dissolution limits using this method will be based on the

    profile from Variant D, not on process capability

    A new way to set specifications

    Future changes such as site, scale, equipment, method of

    manufacture can be qualified using this dissolution method and

    limit

    Question posed to the Agency at recent face to face meeting:

    If we present the clinical boundary of Design Space in this way and

    include the supporting data in the NDA, does this meet the FDA

    expectation of Drug Product design space?

    Developing Process Understanding

    and the Impact on Clinical

    Performance

    - How this might work in practice.

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    An DoE was used to investigate the most important process variables

    relating to the granulation and drying process and subsequent process

    steps.All at the commercial scale

    The most important variables have been further investigated using a

    Response Surface Design

    All batches were tested by the discriminatory dissolution method to

    investigate the impact on clinical performance

    Outputs from the processing studies

    DissolutionProfile of Process OptimisationBatches Compared to Variant C & D

    Time(minutes)

    %D

    issolved

    P/4156/1A

    P/4156/1B

    P/4156/2A

    P/4156/2B

    P/4156/3A

    P/4156/3B

    P/4156/4A

    P/4156/5A

    P/4156/5B

    P/4156/6A

    P/4156/6B

    VariantC

    VariantD

    DissolutionProfile ofProcessOptimisationBatches Comparedto VariantC & D

    Time(minutes)

    %D

    issolved

    P/4156/7A

    P/4156/7B

    P/4156/8A

    P/4156/8B

    P/4156/9A

    P/4156/9B

    P/4156/10A

    P/4156/10B

    P/4156/11A

    P/4156/11B

    VariantC

    VariantD

    DissolutionProfile ofProcess Optimisation Batches ComparedtoVariant C & D

    Time (minutes)

    %D

    issolved

    P/4156/12A

    P/4156/12B

    P/4156/13A

    P/4156/13B

    P/4156/14A

    P/4156/14B

    P/4156/15A

    P/4156/15B

    P/4156/16A

    P/4156/16B

    Variant C

    Variant D

    We have demonstrated that

    Product manufactured at the extremes of the manufacturing parameters

    studied exhibits a dissolution profile significantly faster than variant D

    Therefore, all variants within the manufacturing parameters studied will

    be bioequivalent

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    Proposed control strategy

    Discriminatory dissolution method with a limit based on variant D will

    be used to control the clinical boundary of the Design Space

    For future manufacturing operations within the proven ranges no

    dissolution testing will be performed for release

    For future manufacturing operations outside the proven ranges the

    discriminatory dissolution method will be use to qualify the changes

    Question posed to the Agency at recent face to face meeting:

    If we implement a control strategy for the Design Space as

    described above does this meet the FDA expectation for drug

    product release and post approval flexibility?

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    Generic Summary/Overview

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    Key steps in ascertaining clinical performance by

    dissolution testing in QbD

    1. Applied scientific and risk based thinking

    based on prior knowledge of this and other products

    2. Quality Risk Assessment (QRA) allows the most relevant risk to clinicalquality to be identified

    based on prior knowledge of this and other products

    3. Develop dissolution test(s) with physiological relevance that is most likely toidentify changes in the relevant manufacturing variables, e.g. testing atlowest acceptable solubility/mild agitation.

    4. Understand the importance of changes to these most relevantmanufacturing variables on clinical quality based on dissolution datacombined with

    BCS based prior knowledge

    and/or clinical bioavailability data

    5. Establish the dissolution limit which assure clinical quality (i.e. no effect bychanges)

    Clinical bioavailability/exposure data

    Classical IVIVC (already accepted today in SUPAC)

    In vivo safe space

    Prior knowledge (BCS)

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    Understanding clinical importance of relevant

    manufacturing variables role of dissolution and BCS

    1

    3

    2

    4

    Dissolution should be

    acceptable, provided no new

    excipients affecting transit or

    permeability

    Dissolution accepted Dissolution combined with

    bioavailability study on most

    relevant

    manufacturing/product

    variables

    Bioequivalence Study

    Or

    Follow principles of BCS2 or

    BCS3 if can demonstrate that

    compound behaves more like

    BCS2 or BCS3 in vivo

    SolubilityHigh Low

    PermeabilityH

    igh

    Low

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    Why dissolution testing acceptable surrogate for

    clinical for class III drugs in QbD

    Modelling indicates that class III drug products with rapid dissolution isinsensitive to changes in dissolution, eg

    Difference Cmax

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    The dissolution limits which assure clinical quality by BCS

    Class

    1

    3

    2

    4

    Complete dissolution within

    15 minutes in most

    discriminating simple media

    (physiological pH range). If

    slower: bioavailability data or

    additional mechanistic

    information

    Complete dissolution within

    30 minutes in most

    discriminating simple media

    (physiological pH range). If

    slower: bioavailability data or

    additional mechanistic

    information

    Limit set based on clinical

    bioavailability data

    Limit set on case by case

    basis

    SolubilityHigh Low

    PermeabilityH

    igh

    Low

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    Setting a BCS 2 dissolution limit that assures clinical

    quality based on BA data two acceptable approaches

    Classical IVIVC Safe space*

    in vitro dissolution

    CmaxorAUC

    in vitro dissolution

    CmaxorAUC*A *A

    *B

    *C

    *B *C

    A = biobatch,

    B and C = side batches based on most relevant manufacturing variables

    *For this type of approach to be acceptable the most relevant risks to clinical

    quality need to have been assessed (i.e. in a QbD setting)

    10%

    limit limit

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    Conclusions

    Dissolution testing should be applicable to assuredesired clinical performance for wide range ofdrugs in QbD based on BCS considerations andspecific product knowledge

    Failure to establish classical IVIVC, could besuccesful outcome of in vitro/in vivo study incontext of QbD, if all variants produce the sameexposure