QbD in Theory and Practice
The pharmaceutical industry has sometimes been slow to embrace ideas that promise great practical benefits. The industry’s ingrained aversion to risk is partly to blame, but it’s usually not the whole story. Take the quality-by-design (QbD) initiative, which posits that the better a company understands a product’s quality attributes, the more likely that product will be safe and efficacious. The industry has generally supported this initiative, and Pfizer has brought it into the spotlight.
Understanding critical quality attributes will help Pfizer develop robust design spaces and, ultimately, achieve real-time release, said Gerry Migliaccio, senior vice-president of network performance for Pfizer Global Supply, according to In-Pharma Technologist. Migliaccio made his remarks at a meeting of FDA’s Advisory Committee for Pharmaceutical Science and Clinical Pharmacology. Using QbD as a basis, and process analytical technology to establish manufacturing controls, Pfizer believes it will be able to reduce quality-control costs, achieve real-time release, and quickly get a return on its investment.
But not all companies are rushing to adopt QbD. Manufacturers of small-molecule generic drugs fear that spending the extra initial time and effort to adopt QbD could prevent them from being the first to file an application for their products. “If you’re not first to file, you may as well be last,” said Yatindra Joshi, vice-president of generics R&D for Teva, at the same FDA meeting. Consequently, some generic-drug manufacturers aren’t willing to gamble that the benefits of QbD will outweigh the profits lost by not being first to file.
If Pfizer and other heavyweights adopt QbD, it could boost patients’ confidence in the safety and efficacy of marketed drugs. But patients would benefit even more if generic-drug manufacturers felt freer to pursue this initiative. By making some elements of QbD mandatory in filings, FDA could “level the playing field,” said Joshi. This idea seems like one plausible solution that could be of advantage to the industry and consumers alike.
For FDA’s evaluation of the QbD program so far, please watch for Pharmaceutical Technology’s September issue, in which CDER’s Helen Winkle and Moheb Nasr analyze the initiative’s present and future.
It is getting a little old llstening to those “not in the know” write about how slow industry is adopting QbD. What they may not realize is that QbD was “born” in industry in the early 1970’s. Scientists @ Merck, like the late Joe Schwartz, were breaking ground by applying then new methods of DOE to understand their processes. Search the literature and you will also find scientific journal articles documenting the application of SPC to setting appropriate specs and being used to support a successful validation by showing minimal variability in a process.
Although many report that there are financial benefits to using QbD, they have been elusive. Our industry is ultra conservative and if there was a cost savings it would have already been embraced.
You don’t need to be a black belt to do a literature search to see what industry has already accomplished without the fanfare of QbD. You don’t need to be a financial wizard to know the difference in fictiion and fact when it comes to cost savings.
So stop the whining about how slow industry is to adopt- you’re only confirming your own ignorance.