Oct 29, 2015
SUPACSUPAC
Scale-Up and Post Approval Changes
What are SUPAC documentsWhat are SUPAC documents series of documents issued by US FDA (CDER) to
help applicants with post-approval changes Documents are categorized into IR, MR and SS
(FPPs) Various types of changes are described:
Components and composition Manufacturing (equipment, process) Batch size Manufacturing site changes
SUPAC documents for quality SUPAC documents for quality assessmentassessment
SUPAC IR (immediate release)
SUPAC MR (modified release)
SUPAC IR/MR equipment addendum
SUPAC IR Q&A
SS: Nonsterile semi-solids + equipment addendum
SUPAC documentsSUPAC documentsTreat as supportive documents only
to understand the significance of changes to assist in decision-making
In addition:This guideline can be used to determine whether strengths of a product can be considered proportional, if they are not strictly proportional (i.e. small changes in excipients between strengths).This allows for a decision as to whether in-vivo studies on only a single strength may be sufficient (proportional strength biowaiver).
Introduction to SUPAC IR guidanceIntroduction to SUPAC IR guidance
SUPAC guidelines define:
1.Levels of change
2.Recommended chemistry, manufacturing and controls (CMC) for each level of change
3.In-vitro and/or in-vivo requirements for each level of change
4.Required documentation to support the change
Introduction to SUPAC IRIntroduction to SUPAC IR
Two key areas: Changes to components and composition
Changes to manufacturing (equipment, process)
Components and compositionComponents and composition
Components and Components and compositioncomposition
Levels of change: likelihood of impact on formulation quality and performance
Level 1: unlikely to have detectable impact
Level 2: could have significant impact
Level 3: likely to have significant impact
Components and compositionComponents and composition
Level 1 changes: quantitative only (except IR: colour, flavour, ink; MR: + preservative).
Level 2 changes: quantitative > Level 1, plus any change in excipient grade (MR: + change in excipient specifications).
Level 3 changes: quantitative > Level 2, plus addition or deletion of an excipient (except for a colour, flavour, ink).
Excipients - NoteExcipients - Note
Know your excipients: Description
Grades (when provided) Use in the formulation (e.g. MCC change stated
to be diluent change, when formulation uses it as binder)
Composition Level 1/2 Composition Level 1/2 ChangesChanges
Excipient % Excipient L1 L2
Filler 5 10Disintegrant
Starch 3 6Other 1 2
Binder 0.5 1
Composition Level 1/2 Composition Level 1/2 ChangesChanges
Excipient % Excipient Lubricant L1 L2
Calcium (Ca) orMagnesium (Mg) Stearate 0.25 0.5Other 1 2
GlidantTalc 1 2Other 0.1 0.2
Film Coat 1 2TOTAL ADDITIVE EFFECT 5% 10%
Composition Level 3 ChangesComposition Level 3 Changes
Any change beyond level 2 OR: Any level 2 change for a BCS class 4 (low
solubility and low permeability) or narrow therapeutic drug
Drugs not meeting the level 2 dissolution testingFor both level 2 and level 3 changes, the therapeutic range, solubility and permeability are factors to consider.
Recommended documentation level 1Recommended documentation level 1
Stability testing: one batch on long-term stability data reported in annual report.
Supportive dissolution data: none
Supportive in-vivo bioequivalence testing: none
Recommended documentation level 2Recommended documentation level 2
Requirements for level 2 include stability testing, dissolution testing and possibly an in-vivo study (depending on the results of dissolution testing). IR guideline: the dissolution testing required depends on the BCS class of the API.MR guideline: the dissolution testing depends on the type of release of the FPP.
Recommended documentation level 3Recommended documentation level 3
Requirements for level 3 include stability testing, dissolution testing and an in-vivo study.
SUPAC and Composition - SummarySUPAC and Composition - Summary
SUPAC does: discuss relative changes in formulation discuss supporting data to support a change give an idea of how to consider various changes by looking at the change coupled with the API characteristics
SUPAC does not: substitute for critical thinking (e.g. formulation changes for modified release products)
ManufacturingManufacturing
Manufacturing Process ChangesManufacturing Process Changes
Level 1: changes to parameters (e.g. mixing times, operating speeds) within application/validation ranges
Level 2: changes to parameters (e.g. mixing times, operating speeds) outside application/validation ranges
Level 3: change in the type of process, such as from granulation technique to direct compression of dry powder
Manufacturing Process ChangesManufacturing Process Changes
Recommended documentation:
Level 1: one batch on long-term stability data reported in annual report.
Level 2: stability, dissolution
Level 3: stability, dissolution, and BE study
Manufacturing Equipment ChangesManufacturing Equipment Changes
Equipment is categorized according to
Class: operating principle
Subclass: design characterization
Equipment categorizationEquipment categorization
SUPAC equipment addenda: aid for considering equipment changes
provides information on equipment categorized according to class (operating principle) and subclass (design characteristics)
gives concise descriptions in context of other classes/subclasses
ManufacturingManufacturing Equipment Changes Equipment Changes
Divided by unit operation: Blending and mixing Drying Particle size reduction/separation Granulation Unit dosing (tabletting, encapsulating, powder
filling) Coating and printing Soft gelatin capsule encapsulation
Example class/subclass:Example class/subclass:Blending and MixingBlending and Mixing
Class: Diffusion (tumble) mixers:Subclasses: V-blenders Double Cone Blenders Slant Cone Blenders Cube Blenders Bin Blenders Horizontal/Vertical/Drum Blenders Static Continuous Blenders Dynamic Continuous Blenders
Equipment categorization exampleEquipment categorization example
Class (operating principles) diffusion/tumble mixers: Particles are reoriented in relation to one another when they are placed in random motion and interparticular friction is reduced as the result of bed expansion (usually within a rotating container);
Subclasses (design characteristics) for diffusion mixers are distinguished by geometric shape/positioning of axis of rotation.
Example class/subclass:Example class/subclass:Blending and MixingBlending and Mixing
Manufacturing Equipment ChangesManufacturing Equipment Changes
Level 1: 1) change from non-automated or non-mechanical equipment to automated or mechanical equipment to move ingredients; and 2) change to alternate equipment of the same design and operating principles of the same or of a different capacity.
Level 2: change to equipment of different design and different operating principles
Manufacturing Equipment ChangesManufacturing Equipment Changes
Recommended documentation:Level 1: one batch on long term stabilityLevel 2: stability, dissolution
SUPAC limitationsSUPAC limitations
SUPAC limitations SUPAC limitations Formulation/ManufacturingFormulation/Manufacturing
SUPAC: has not been updated (1995/97 for main guides, 1998/99 for equipment addenda) does not discuss multiple changes does not directly cover same class, different
subclass for equipment does not cover modified equipment must be used in conjunction with other
references, e.g. excipient handbook
ConclusionConclusion
For new (to you) and unique situations:
Consult! Those with related experience Senior assessors BE assessors
AvailabilityAvailability
Go to: www.fda.gov Drugs Guidance, Compliance & Regulatory
InformationOR directly:http://www.fda.
gov/Drugs/GuidanceComplianceRegulatory
Information/Guidances/default.htm
SUPACWhat are SUPAC documentsSUPAC documents for quality assessmentSUPAC documentsIntroduction to SUPAC IR guidanceIntroduction to SUPAC IRComponents and compositionComponents and compositionComponents and compositionExcipients - NoteComposition Level 1/2 ChangesComposition Level 1/2 ChangesComposition Level 3 ChangesRecommended documentation level 1Recommended documentation level 2Recommended documentation level 3SUPAC and Composition - SummaryManufacturingManufacturing Process ChangesManufacturing Process ChangesManufacturing Equipment ChangesEquipment categorizationManufacturing Equipment ChangesExample class/subclass: Blending and Mixing Equipment categorization exampleExample class/subclass: Blending and MixingManufacturing Equipment ChangesManufacturing Equipment ChangesSUPAC limitationsSUPAC limitations Formulation/ManufacturingConclusionAvailability