Question-based Review (QbR) at the Center for Veterinary Medicine
Dennis M. Bensley Jr., Ph.D. Director Division of Manufacturing Technologies FDA/OF/CVM/ONADE FDA/PQRI Conference September 2014
General Outline Background on CMC Filing Requirements QbR at CVM
QbR and eSubmitter Advantages of QbR
Future QbR activities
Federal Food, Drug, and Cosmetic Act Section 512(b)(1) of the Federal Food, Drug, and Cosmetic (FFD&C) Act requires that animal drug applicants: identify all of the components of the drug provide the composition or formulation of the drug provide a full description of the methods, facilities, and controls used in the manufacture, processing and packing of the drug
3
Code of Federal Regulations The Code of Federal Regulations (CFR), 21 CFR 514.1(b), provides additional information on CMC filing requirements 21 CFR 514.1(b)(4) and (5) were commonly used templates to format original CMC submissions
4
QbR at FDA • The QbR concept was pioneered at FDA by CDER’s Office of Generic Drugs (OGD) • CVM adapted the QbR concept for CMC information filed in original generic and pioneer animal drug submissions • CVM’s QbR process covers the submission of CMC information for Drug Substance, Drug Product, and Sterile Process Validation
5
Development of QbR at CVM • QbR at CVM was developed based on:
OGD’s QbR Current filing requirements for (A)NADAs Current CVM guidance documents Input from CVM reviewers Input from regulated industry
6
QbR at CVM • CVM has presented webinars to share the QbR concept with the regulated industry and the public • Drug Substance, March 2010 • Drug Product, July 2010 • Sterile Process Validation, February 2011
• QbR is the basis of the eSubmitter template for the CMC Technical Section 7
Sterile Process Validation QbR at CVM
When developed, no published QbR available from OGD, unlike Drug Substance/Drug Product document Based roughly on Guidance for Industry for sterile process validation Content level questions based on current review practices
Additional questions based on industry feedback 8
Sterile Process Validation QbR at CVM
• Sterile process validation QbR covers: Terminal Sterilization
Moist Steam • Radiation •
Aseptic Processing Microbiological Methods
9
QbR Format Common Technical Document (CTD) M4Q: The CTD Quality
Module 2 – CTD Summaries 2.3 Quality Overall Summary (QOS) QbR is contained within this section
Module 3 – Quality 3.2 Body of Data
10
QbR Format
Section/Module 2 – CTD Summaries Overview of the CMC aspects of the submission 2.3.S (drug substance) 2.3.P (drug product)
Section/Module 3 – Quality Supporting data containing the details of the CMC submission 3.2.S (drug substance) 3.2.P (drug product) Sterile process validation
Section 4 – Sterile Process 11
CVM’s QbR Format High-level question Detailed question Questions commonly asked by the sponsor
12
CVM’s QbR Format • High-level question are the critical questions that should be answered to address product quality – Detailed question are intended to clarify what information is needed to address the high level question • Questions commonly asked by the sponsor provide additional explanation about the question and suggestions for formatting the response
13
Example Drug Substance: Manufacture What are the manufacturing processes and controls and how do they ensure consistent production of the drug substance? What are the filling procedures for the primary container-closure system? Can a different manufacturing process/facility be used for the pilot batches?
14
2.3.S
Drug Substance
2.3.S.1 General Information 2.3.S.2 Manufacture 2.3.S.3 Characterization 2.3.S.4 Control of Drug Substance 2.3.S.5 Reference Standards 2.3.S.6 Container Closure System
2.3.S.7 Stability 15
2.3.P Drug Product 2.3.P.1 Description and Composition 2.3.P.2 Pharmaceutical Development Report
2.3.P.3 Manufacture 2.3.P.4 Control of Excipients 2.3.P.5 Control of Drug Product 2.3.P.6 Reference Standards and Materials 2.3.P.7 Container Closure System 2.3.P.8 Stability 16
Section 4 – Sterility 4.1 Moist Steam Sterilization 4.2 Radiation Sterilization 4.3 Aseptic Processing 4.4 Component Preparation 4.5 Microbiological Monitoring of the Environment
4.6 Microbiological Testing Controls and Stability Considerations 4.7 Process Control Documentation
4.8 Microbiological Testing Controls 17
QbR and eSubmitter • All three sections of QbR document are present in the (J)INAD P MC Template for the eSubmitter • Drug Substance (28 high level/detailed questions) • Drug product (113 high level/detailed questions) • Sterile Process Validation (164 high level/detailed questions)
• The questions you see in the eSubmitter are similar to published QBR documents 18
What is eSubmitter? An electronic question based system to create and submit information to ONADE
Used by sponsors to build and submit their correspondence Submission is contained within a single ZIP file
Files attached can be XML, PDF, and SAS Xport file formats
19
What is eSubmitter?
– eSubmitter will be the sole electronic submission tool for ALL submissions to CVM-ONADE, including:
(J)INADs – all technical sections, protocols, etc. (A)NADAs – Original, supplements, and MCSRs VMFs – Original, supplements, and annual reports GCs – User Fees waiver requests, etc.
20
How does eSubmitter work? Uses data capturing forms (question and answer, file attachment capability, etc.) to walk users through the process of compiling a complete and structured submission to FDA Uses business rule logic (conditional statements) to require the submitter to complete sections based on previous responses 21
eSubmitter Example
eSubmitter Example
Using eSubmitter
• Paper submissions will continue to be accepted, and will be scanned to be reviewed electronically • For additional information about eSubmitter visit: http://www.fda.gov/ForIndustry/FDAeSubmitter/default.htm
24
Advantages of QbR Provides more transparency to applicants Provides focus for CVM reviewers
% One-cycle CMC review (INAD-P) 80
60
Increase in one-cycle reviews
40 20 0 CY'09 CY'10 CY'11 CY'12 CY'13
Flexible process to provide guidance Positive feedback from reviewers and sponsors
25
Future of QbR in CVM Continued modifications based on stakeholder and reviewer feedback; and new regulatory science Expansion to non-CMC submissions: Establish QbR process for bioequivalence submissions by end of FY’16 (see AGDUFA 2 re-authorization performance goals and procedures)
Protecting both Human and Animal Health THANK YOU!!