CRED Getting the CMC Dossier Right 2024
28/08/2024
Lifecycle FPS (1)
• Limited data may be available at time of filing which influences specification setting
• FPS is part of continuous improvement, needing revision as manufacturing experience is gained and changes to API, excipients, container closure system, manufacturing facilities and analytical methods
• ICH Q14 Technical and Regulatory Considerations for Pharmaceutical Product Lifecyle Management
• FPS is defined as an Established Condition that assures product quality • Requires a regulatory communication, if changed • Major change, prior approval - e.g. widening of acceptance limits • Minor change, prior approval - e.g. adding/replacing a test method resulting from a safety/quality issue • Notifications, no prior approval – e.g. Adding new test, tightening acceptance limits, complying with pharmacopoeia, etc.
Decreasing impact on product
The Organisation for Professionals in Regulatory Affairs
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Commercial FPS
US JP
EU
EU
Test
Test methods
Release
Shelf-life
Stability
Appearance
Visual
White, round, flat tablet. 7.5mm dia. x 5mm
White, round, flat tablet. 7.5mm dia. x 5mm
White, round, flat tablet. 7.5mm dia. x 5mm
Identification
IR
Complies with reference
Complies with reference
Not tested
HPLC-UV
Complies with reference RT
Complies with reference RT
Not tested
Assay
HPLC-UV
95.0% to 105.0%
93.0% to 105.0%
93.0% to 105.0%
Related substances
Impurity A
0.2%
0.5%
0.5%
Unspecified
HPLC
0.2%
0.2%
0.2%
Total impurities
1.0%
2.0%
2.0%
Dissolution, 45 min
Ph. Eur. 2.9.3
Q=80%, 30 min
Q=80%, 30 min
Q=80%, 30 min
Uniformity of dosage units
Ph. Eur. 2.9.40
Complies
Complies
Not tested
Water
Ph Eur 2.5.12
0.5%
1.0%
1.0%
TAMC 10 3 CFU/g TYMC 10 2 CFU/g Absence of E. coli
TAMC 10 3 CFU/g TYMC 10 2 CFU/g Absence of E. coli
TAMC 10 3 CFU/g TYMC 10 2 CFU/g Absence of E. coli
Microbial quality (annually or every 10 th batch whichever is sooner)
Ph. Eur. 2.6.12 & 2.6.13
The Organisation for Professionals in Regulatory Affairs
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11
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