MSD K.K, Kitanomaru Square, 1-13-12 Kudan-kita, Chiyoda-ku, Tokyo, 102-8667, Japan.
Department of Pharmaceutical Sciences, Tokyo University of Science, Tokyo, Japan.
Ther Innov Regul Sci. 2020 Sep;54(5):1192-1198. doi: 10.1007/s43441-020-00146-y. Epub 2020 Mar 24.
For pharmaceutical products, an in-depth understanding of manufacturing processes and quality risks associated with quality by design (QbD) development enables the production of high-quality products. Product recall due to quality issues could be minimized for QbD-developed products. Furthermore, the review period instituted by regulatory authorities could be shortened by allowing reviewers to access technical documents with QbD elements. The aim of this study was to examine the impact of QbD development from the viewpoints of regulatory flexibility, product quality related to recall, and review period in Pharmaceuticals and Medical Devices Agency (PMDA) in Japan.
QbD developments for new active ingredients, approved from 2009 to 2018, were surveyed in the PMDA review reports, and review periods were investigated on the PMDA website. Voluntary product recalls and their rationale were investigated using the website of the Japan Ministry of Health, Labour and Welfare.
Although the developmental ratio with QbD elements was increased from 9% in 2009 to 71% in 2018, the development of design space for drug substances and products between 2009 and 2018 was only 2%, and real time release testing (RTRT) for drug products was limited to 3%. Voluntary recall and extension of the review period for QbD-developed products were not observed.
The advantages of systematic QbD development were suggested for no voluntary recall of QbD-developed products. Conversely, applicants did not actively seek regulatory flexibility with design space or RTRT, and QbD development failed to impact the PMDA review period.
对于制药产品,深入了解与质量源于设计(QbD)开发相关的制造工艺和质量风险,能够生产出高质量的产品。通过 QbD 开发的产品可将因质量问题导致的召回降至最低。此外,允许审核人员访问具有 QbD 要素的技术文件,可缩短监管机构设定的审核周期。本研究旨在从监管灵活性、与召回相关的产品质量以及日本药品和医疗器械管理局(PMDA)的审核周期这三个角度,考察 QbD 开发的影响。
在 PMDA 的审核报告中调查了 2009 年至 2018 年获批的新型活性成分的 QbD 开发情况,并在 PMDA 网站上调查了审核周期。使用日本厚生劳动省的网站调查了自愿产品召回及其基本原理。
尽管具有 QbD 要素的开发比例从 2009 年的 9%增加到 2018 年的 71%,但 2009 年至 2018 年药物物质和产品的设计空间开发仅为 2%,并且药物产品的实时放行检测(RTRT)也仅为 3%。未观察到 QbD 开发产品的自愿召回或审核周期延长。
对于 QbD 开发产品没有自愿召回,表明系统性 QbD 开发具有优势。相反,申请人并未积极寻求设计空间或 RTRT 的监管灵活性,QbD 开发也未对 PMDA 审核周期产生影响。