Process Validation Module Challenge: Miss Wormwood fell and broke her hip and has to have surgery. Due to her age, cigarette smoking habit, being overweight, and having been bed-ridden since the fall that caused the break, she is at risk for a pulmonary embolism. Although Calvin may present the attitude that he does not care about the course material, he now sees a legitimate reason why what he has learned in his class is so important. The hospital plans to give Miss Wormwood a recombinant therapeutic protein to prevent a pulmonary embolism. Calvin wants to do his best to understand how the pharmaceutical company that produces the protein (that also retained his father as a patent attorney) insures that the protein is not only effective but safe for her to take. Generate Ideas: In class, have students make journal entries to answer the following five questions: (1) what are your initial ideas about how recombinant therapeutic proteins are produced? (2) What are the critical process parameters in each process step? If you don‟t know, how would you determine what they are? (3) For each process step, how many and what types of measurements would you make to ensure that the process design is consistent? (4) How would you document this? (5) Who would need to approve your methods and why? Multiple Perspectives: In the whole-class setting, have the students share ideas from their journals. Formatively evaluate these to assess if students see the need for a clear understanding of (1) the protein production process, (2) the critical process parameters associated with each step of the process, and (3) the need to measure, validate and document each process step to insure reproducibility, safety and efficacy. Next, read the expert interview of Dr. William Hall that will guide the students to see the need for a process validation program. Work with students in a discussion format to create a plan of action and required knowledge. Process Validation Module Multiple Perspectives An Interview with Dr. William E. Hall, Hall & Pharmaceutical Associates, Inc. 1. If I have an infection and am given an antibiotic, how do I know that the dose is the same? If the company manufacturing the product is a reputable manufacturer, then they have to prove that the dose is the same in each and every dose. Now of course they are allowed some variation to account for variation due to manufacturing and analytical variation. After all, the products were made by humans so there is some slight variation, but usually not more than + or – 10% for an antibiotic, even less for a non-antibiotic product. The test that the company that manufactured the product must run is known as a „content uniformity‟ test, which is pretty self-explanatory (i.e. content uniformity is the test to see if the dose is the same or uniform from one tablet to the next. During the development phase of the product the company tests many thousands of tablets to gather the data that proves that the product will deliver a uniform dose consistently from one dose to the next. (If I should happen to meet you in person ask me about a situation in Australia when the company made a product that did not have good content uniformity.) 2. Who is responsible for determining that each dose is the same? The responsibility for determining that the dose will be uniform or the same is a shared responsibility. The pharmacists in the research and development department (usually known as R and D) are responsible for finding out how to make the product uniform during the development stage. They determine such critical factors as how much mixing is required to uniformly distribute the active ingredient throughout the other ingredients in the product (known as excipients) that will be compressed into tablets to make the product.
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Process Validation Module
Challenge: Miss Wormwood fell and broke her hip and has to have surgery. Due to her age, cigarette smoking
habit, being overweight, and having been bed-ridden since the fall that caused the break, she is at risk for a
pulmonary embolism. Although Calvin may present the attitude that he does not care about the course material, he
now sees a legitimate reason why what he has learned in his class is so important. The hospital plans to give Miss
Wormwood a recombinant therapeutic protein to prevent a pulmonary embolism. Calvin wants to do his best to
understand how the pharmaceutical company that produces the protein (that also retained his father as a patent
attorney) insures that the protein is not only effective but safe for her to take.
Generate Ideas: In class, have students make journal entries to answer the following five questions: (1) what are
your initial ideas about how recombinant therapeutic proteins are produced? (2) What are the critical process
parameters in each process step? If you don‟t know, how would you determine what they are? (3) For each
process step, how many and what types of measurements would you make to ensure that the process design is
consistent? (4) How would you document this? (5) Who would need to approve your methods and why?
Multiple Perspectives: In the whole-class setting, have the students share ideas from their journals. Formatively
evaluate these to assess if students see the need for a clear understanding of (1) the protein production process, (2)
the critical process parameters associated with each step of the process, and (3) the need to measure, validate and
document each process step to insure reproducibility, safety and efficacy.
Next, read the expert interview of Dr. William Hall that will guide the students to see the need for a process
validation program. Work with students in a discussion format to create a plan of action and required knowledge.
Process Validation Module
Multiple Perspectives
An Interview with Dr. William E. Hall, Hall & Pharmaceutical Associates, Inc.
1. If I have an infection and am given an antibiotic, how do I know that the dose is the same?
If the company manufacturing the product is a reputable manufacturer, then they have to prove that the dose
is the same in each and every dose. Now of course they are allowed some variation to account for variation
due to manufacturing and analytical variation. After all, the products were made by humans so there is some
slight variation, but usually not more than + or – 10% for an antibiotic, even less for a non-antibiotic
product. The test that the company that manufactured the product must run is known as a „content
uniformity‟ test, which is pretty self-explanatory (i.e. content uniformity is the test to see if the dose is the
same or uniform from one tablet to the next. During the development phase of the product the company tests
many thousands of tablets to gather the data that proves that the product will deliver a uniform dose
consistently from one dose to the next. (If I should happen to meet you in person ask me about a situation in
Australia when the company made a product that did not have good content uniformity.)
2. Who is responsible for determining that each dose is the same?
The responsibility for determining that the dose will be uniform or the same is a shared responsibility. The
pharmacists in the research and development department (usually known as R and D) are responsible for
finding out how to make the product uniform during the development stage. They determine such critical
factors as how much mixing is required to uniformly distribute the active ingredient throughout the other
ingredients in the product (known as excipients) that will be compressed into tablets to make the product.
After the product is developed and marketed, then the responsibility for making sure that the dose is the
same today, tomorrow, and forever falls to the Quality Department of the company. This department is
divided into Quality Assurance, who makes sure that the production department carries out the procedure
the same way for every batch by auditing them daily and the Quality Control section which pulls samples
from the production batch and tests them.
3. How do they do it? With what accuracy can they do it? With what accuracy MUST they do it and
why? When do they do it and why? Do they have to record any data? If so, what?
That is a very good question and it will be difficult to give a short answer. The test for antibiotic potency is
done by a method called “zone of inhibition”. This test involves dissolving one tablet into sterile water and
then placing one drop of that solution on a petri dish which is filled with media, which is like a food for
bacteria. The plates are set aside in a nice warm, cozy area and the bacteria are allowed to grow for a certain
period of time (sort of like snacking while watching pro football on Sunday afternoon). The bacteria grow
real fast in the places not close to the drop of antibiotic, but the antibiotic keeps them from growing up close
to the drop. The result is that the drop has a clear area around the drop where no bacteria could grow. The
larger this circle of „no growth‟ the more potent the antibiotic. So by measuring this “zone of inhibition”, the
lab scientist can calculate just how potent the tablet was. The test is run many times and the average result is
calculated.
The accuracy of the test must be at least + or – 5% if not better. The allowable accuracy is determined by a
combination of the accuracy of the test and the variability in the technique of the laboratory person
performing the test. This is one of the reasons that the lawyers attack the lab results in court (think CSI)
because if they can show that the lab scientist did not use proper technique, they can invalidate the results
and their client can be exonerated of the charges against him or her.
The tests on all products must be done before the product is released and allowed to be sold. Thus, the proof
of quality must be determined by testing before the product can even be moved from the quarantined area
and onto the trucks for shipment.
The test data must be reviewed by a laboratory supervisor as a part of the final product release process for
each individual product batch. The data is also reviewed by the FDA (Food and Drug Administration)
inspectors when they perform inspections of every manufacturing facility every two years. So there are
many checks of the data and the laboratory must comply with every aspect of the regulations as specified in
great detail in the current Good Manufacturing Practices (cGMP) Regulations as well as the current Good
Laboratory Practices (cGLP) Regulations. These are regulations, i.e. they are not optional.
4. Does someone check behind them to make sure they are not making a mistake? Who and how? Does
their criteria for checking change? Why and how often? What drives change?
I actually answered the first parts of your question in the previous answer. However, the last part of your
question is very interesting and also very good. The best part to answer first is the last part of your question,
i.e. “what drives change?” Change is driven by changes in drug therapy (the acceptable dosage for certain
drugs, especially new drugs sometimes changes as well develop more experience with treatment of different
medical conditions. Changes also occur due to the technology. As you know, the laboratory scientists are
always developing new and better methods of assaying products and this results in changes in the way that
we test the products. Techniques are available today that were not available as recently as 5 years ago. For
example, today‟s analytical methods are able to detect drugs with a sensitivity of 1 part per billion (ppb),
that is 1 part in 1,000,000,000 and less. That is totally awesome! We are using these powerful tools to learn
constantly about our drugs.
Another driving force for change is the improvement in how drugs are administered to the patient resulting
in more of the drug getting to the place in the body where it is actually needed. For example, if you have an
infection in your foot and you take an antibiotic tablet, you might be surprised to know that only a small
fraction of what you took actually reaches your infected foot. This concept, known as bioavailability, is very
important. For instance, say you take 500 mg of an antibiotic. Maybe a few years ago, only 100 mg of that
500 was actually absorbed into your body. The other 400 mg was excreted in the feces or urine and never
did you any good at all. The pharmaceuticals scientists have found ways to administer drugs in the last few
years that give a greater percentage of bioavailability. Thus instead of giving you a 500 mg tablet, they can
give you a 100 mg tablet. This is the case where less is actually more. Why? Because along with every drug
comes side effects – these are the bad things that can happen to you when you take the drug, such things as
extreme nausea, diarrhea, and vomiting. You don‟t want to go there- right? Well, one good thing about
decreasing the dose of most drugs is that by doing so you also decrease the undesirable side effects. Perhaps
you‟ve heard about people who have cancer and have terrible attacks of nausea. Well, the last few years
they have found ways to give the drugs for cancer than increase the bioavailability, thus decrease the side
effects such as nausea. The patient may also be less likely to lose their hair with certain anti-cancer drugs.
So we are making some progress.
5. Do they check periodically to make sure that what they said they could do they could indeed do? How
frequently?
All reputable drug companies are constantly evaluating their products. They do this by a variety of methods.
First, they actually go to the companies that make the ingredients for their products and inspect them. They
know that their products can be of no better quality than their starting materials. “Garbage in – garbage out”
is not just a computer cliché.
They also must keep a retained sample of every batch of product released to the market. If they get a
complaint from a patient or from a doctor that the product did not physically look as it should (and patients
know what their medicine should look like) or if the drug does not give the desired or expected effect, then
the company wants to know about it and they will then test the retained sample of the specific batch to see if
it is still full potent. This „feedback‟ from real people is very important to tracking the performance of the
product.
6. What are the characteristics of a pharmaceutical product that are important to its safety and
efficacy? How are they determined? Are they the same for every product?
There are many measurable characteristics of a pharmaceutical product that contribute to safety and
efficacy. The new drug must be evaluated for any factors could affect its safety and efficacy – such things
as mutagenic, teratogenic, carcinogenic effects as well as toxicity and potency. The drug may be unsuitable
for pregnant patients or even females of childbearing age. There may also be medical conditions for which
the new drug cannot be used, referred to as contraindications. Each of these must be evaluated for every new
product and this „proof‟ must be submitted to the FDA as part of the New Drug Application (NDA). The
first studies are performed on animals to establish how the body metabolizes and excretes the drug and how
toxic the drug is in animals. The most important of these factors is the data gathered during the clinical trials
of the drug during the development phase long before the product reaches the general market. The clinical
trial is actually composed of 3 distinct phases. During phase 1 of the clinical trials, the new drug is tested in
animals in very small, sub therapeutic doses to determine how the body. During phase 2 of the clinical trials,
the drug is administered in small doses to a few human patients in good physical condition, i.e. those not
having any serious medical condition including the medical condition for which the drug will be used. The
purpose of this study is to determine how the drug is metabolized and excreted in humans, how toxic the
drug may be, determine any side effects or contraindications, and get a general idea of what the therapeutic
dose of the drug will be. During phase 3 of clinical trials, the new drug is tested at full therapeutic dose in a
large number of patients.
7. Is everything measured? Does someone say what is important and what is not? Based on what?
Patients are fully characterized during the clinical trials. They are fully evaluated as to physical properties
such as age, weight, and any pre-existing medical conditions are fully documented. The patients are
monitored and measured throughout the study. Placebo doses are administered to determine if the medical
effects are real or imagined.
The most important evaluation of the clinical trial data is that performed by medical personnel that serve as
advisor panels to the FDA. They are subject matter experts (SMEs) who advise the FDA on whether the
drug should be approved or not. They essentially say what is important and what is not and, most
importantly, they answer the question “Does the benefit of having the drug available on the market
outweigh the negative side of adverse drug reactions?” Sometimes it‟s a tough decision.
8. Does how much the manufacturer makes matter? How is it determined how long the product can
last? What does the product expiration date really mean?
The size of the batch does not influence the stability and thus the shelf life of the individual tablets. A given
product will have the same expiration date regardless of whether it is made in a large batch or a small batch
size. However, if a drug is very unstable, then it may be made in another form e.g. a freeze dried powder
which can be reconstituted at the time of use or it might be required to be stored in a cool place to prolong
the activity of the drug.
How long a drug can last depends on the intrinsic stability of the drug in the dosage form and it must again
be experimentally determined. Usually, a drug product is considered no longer fully potent when the
concentration of active ingredient or the amount of active ingredient has decreased to 90 % of its labeled
potency. Thus, if you had an antibiotic product that normal had 500 mg of active ingredient, then if it took 2
years or 24 months for the amount of active to decrease to 450 mg, then the expiration date would be 24
months from the date of manufacture. This expiration date is established by storing the drug in a
temperature controlled cabinet and periodically testing the product, i.e. the expiration date is determined by
real time testing of the product under different conditions of temperature and humidity.
It is important to note that the expiration date and the storage conditions specified on the label are tied
closely together. If the product is labeled with an expiration date of October 2011 and the label specifies
store in a controlled room temperature, and for some reason you leave it on the window sill in your kitchen
where the afternoon sun beats down on it and the temperature reaches over 100 degrees, then the product
will likely not be fully potent until October 2011, i.e. it will go bad before then.
Respectively submitted,
Bill Hall
Research and Revise:
Topic One – Learn/review the protein production process
Review Scientific American & Trends in Biotechnology articles on recombinant proteins. Discuss articles in
class.
Velander, William H., Lubon, Henryk; Transgenic livestock as drug factories. Scientific American, Jan97, Vol.
276, Issue 1
Michael K. Dyck, Dan Lacroix, Franc¸ois Pothier and Marc-Andre´ Sirard. “Making recombinant proteins in
animals – different systems, different applications” TRENDS in Biotechnology Vol.21 No.9 September 2003
Play “Manny the Biotech Goat” board game as review of upstream and downstream bioprocessing.
Manny the Biotech Goat
Developed by Hector Lopez Pelet Validation Contractor
East Carolina University alum
| Instructional Objective | Learners & Context | Object of Game | Game Materials |
| Time Required | Rules | Design Process | References |
Instructional Objective
To present in an interesting way, the process for the manufacture of Antithrombin (ATryn) with emphasis in the Bioseparation techniques involved.
To use the game as an interactive learning experience.
Learners & Context of Use
This game is designed for Biotechnology students of undergraduate level. The game is intended to be played in the classroom as an interactive learning experience for a biotechnology separations techniques course. The game could be used as part of a final course grading tool, to demonstrate student’s proficiency in the subject matter: Principles of Bioseparation Techniques.
Object of the Game
The object of the game is to be the first to reach the end. If played in the classroom as a grading tool, each group of 4 students will compete for the following prices:
1st player to get to the finish gets 10 points for the final exam, or 5 points towards the final course grade.
2nd player to get to the finish gets 8 points for the final exam, or 4 points towards the final course grade.
3rd player to get to the finish gets 6 points for the final exam, or 3 points towards the final course grade.
4th player to get to the finish gets 4 points for the final exam, or 2 points towards the final course grade.
Game Materials
The game is comprised of the following components:
The board game
Player indicator/markers (4 colors)
A dice
Game cards (Question and Answers) colored by specific game sections.
Time Required
Time required for game set-up should not exceed 10 minutes due to the simplicity of design. Game plating should take from 30 minutes to 1 hour for 4 players.
The Rules
The rules for the game are as follows:
1. Each player will select a player marker.
2. Each player will roll the dice to select starting positions. The highest dice value will start first, the second highest will start second, etc.
3. The first area to play will be the yellow path.
4. The first player will select a card from the yellow pack.
5. If correctly answered, the player may roll the dice to advance.
6. If incorrectly answered, player stays at the current step.
7. Afterwards, the next player will repeat.
8. If a player lands in a square with this symbol the player will lose his/her turn to answer a card question.
9. If a player lands in a square with this symbol the player will go back one step.
10. If a player lands in a square with this symbol the player will advance one step and will have the option of selecting a mystery card.
11. The yellow path will contain questions referent to general Bioseparation techniques and issues particular to the process of the creation and generation of transgenic goats for the production of therapeutic protein, in this case Antithrombin III or Atryn.
12. The red path will contain questions referent to general Bioseparation techniques and issues particular to the processing of the milk obtained
from transgenic goats to produce therapeutic protein, in this case Antithrombin III or Atryn.
13. Mystery questions, if correctly answered, can give player extra steps. No penalty for incorrect answers.
14. First player to reach the Start point wins.
Design Process
The design process was based on examples given from past educational board game projects and the reference information obtained, from the course textbook and subject matter articles.
References
The references used for this game where from the course textbook, Journal Articles, and educational board game project examples.
Books & Journals Ghosh, Raja (2006). Principles of bioseparations engineering. Hackensack, NJ: World Scientific.