Form for submission of comments - EFPIA
Final, 23rd June 2014
Submission of comments on the Concept Paper on the establishment of a guideline on the selection of sterilisation processes for drug products’ – EMA/CHMP/CVMP/QWP/128000/2014
Comments from:
|Name of organisation or individual |
|EFPIA – Sylvie Meillerais (sylvie.meillerais@efpia.eu) |
Please note that these comments and the identity of the sender will be published unless a specific justified objection is received.
When completed, this form should be sent to the European Medicines Agency electronically, in Word format (not PDF).
General comments
|Stakeholder number |General comment (if any) |Outcome (if applicable) |
|(To be completed by the Agency) | |(To be completed by the Agency) |
| |EFPIA welcomes the CP and the opportunity to provide comments. | |
| |EFPIA agrees that a revision of existing documents on the selection of sterilisation methods is | |
| |required. However additional clarity on application and/or regulatory expectations is welcome for few | |
| |general items such as: | |
| |The need for biological validation of a terminal sterilisation process; | |
| |Considering how advanced aseptic technologies, such as isolators and closed system processing can play | |
| |a role in the final sterilisation method selection; | |
| |Parametric release and how its principles could be extended to additional sterilisation methods. | |
| |While making the decision to use a particular sterilisation method, it is critical to understand the | |
| |impact to the product caused by the chosen method(s). It is important that this decision remains within| |
| |the discretion of the manufacturer as part of his product knowledge, and should be based on the | |
| |understanding of the product and process, rather than being a ‘simple’ statement about what an | |
| |acceptable level of change in the product might be. | |
Specific comments on text
|Line number(s) of the relevant|Stakeholder number |Comment and rationale; proposed changes |Outcome |
|text |(To be completed by the Agency) |(If changes to the wording are suggested, they should be highlighted using 'track changes') |(To be completed by the Agency) |
|(e.g. Lines 20-23) | | | |
|Section 3. | |Although the Concept Paper does address the need for sterilisation vs. aseptic manufacture of | |
|Discussion | |medicinal products and their development, it should also take into account the manufacture of | |
| | |Investigational Medicinal Products. At early clinical stages, the product knowledge and stability to | |
| | |support currently used terminal sterilisation processes may be limited; in such cases, aseptic | |
| | |manufacturing may be an acceptable alternative approach in the short term, provided that the | |
| | |development program includes appropriate work to gather the data and product understanding needed to | |
| | |make the final sterilisation method decisions. | |
|Section 3. | |The term ‘limited sterilisation assurance level’ in section 3 is unclear. Sterility Assurance Level | |
|Discussion | |is a mathematical concept based on extrapolation of microbial inactivation and should only be applied| |
| | |in the context of a process that inactivates microorganisms. Sterility Assurance level has a value, | |
| | |and so can be higher or lower, but not “limited”. | |
|Section 3. | |The current guidance is specific in clarifying that “inappropriate heat-labile” packaging is not by | |
|Discussion | |itself a reason to use aseptic processing, but then states that this “could be justified if other | |
| | |factors need to be considered”. We believe it is important that this statement is preserved in the | |
| | |future document, and perhaps be expanded to acknowledge that the Quality target product profile in | |
| | |ICH Q8 can include attributes of the primary packaging that are important to the product use and | |
| | |customer needs and that may be impacted by terminal sterilization (i.e. container closure, colour, | |
| | |etc…). | |
Please add more rows if needed.
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