7. Development
Errors of Omission have to be
eliminated by Quality by
Design
Error of Commission have to be
eliminated in Operation by self
authorship of SOPs
23. CAPA are not
Continual Improvement
You can only improve a process
when you are in a state of
control
You canât improve when it is in
need of Corrective &
Preventive Actions
25. 75 years of Independence
No new molecules,
Dependent on import for
Knowledge, Technology,
Equipment,
Materials, Excipients, Etc. etc.
Poorly sensitized to real time
observations & real world
evidences
27. On one table
Subject matter experts,
determination, science, real
world evidence, real world
experience, real world data,
measurement, knowledge
& wisdom
28. Shortening of Drug Production Cycle
Data Science & Artificial Intelligence
Future
Patient
31. Analytical method and the state of
control is key to determine process
control
Traditional practices are no longer
science based & to convert to science
based is
Maturity
32. Inherent limitations and block
From uni-variate thinking
to Multivariate Quality
Risk Management
Simply compendial
tests does not tell that
batch is ok
33. Chaos is a system that is
unpredictable beyond average âŠ.
inability to understand extreme
sensitivity
Uncertainty &
Expectation Management
34. GMP ... Q10 ⊠Maturity
What habits and
practices need to be
changed?
35. Are they falling
down again and do
we need to get them
back up
Is this a firm that is
much more mature,
has higher level of
quality and they
slipped
Just need to help
them a little bit
Need meeting or
something more
aggressive
36. Are the findings the
tip of the ice berg or
just an isolated case?
Is this a bigger thing
that affects other
drugs or other lots?
Is it an episodic
event?
38. Sustainable Compliance
Continue to encourage
companies to think about
not only meeting the
minimal expectations but
how to achieve a level of
sustainable compliance
46. Flexible Production Entering New Domains
Integrated Quality
A siteâs ability to accommodate change
in production demand
47. Balanced and integrated quality system
Flexible Production Entering New Domains
Integrated Quality
48. Having the ability to quickly absorb
knowledge to implement new practices
Flexible Production Entering New Domains
Integrated Quality
49. Capability to provide
patients real time
information about
their condition and
collect patient data
for care analytics to
improve the
treatment
Beyond the Pill
54. Differences in impurities are
acceptable, but
Generics should demonstrate
that this would not increase a
productâs risk
Synthetic
Peptide Drug
Products
55. For any new impurity
Greater than 0.5%
is not acceptable, it must be
less than 0.5%
Synthetic
Peptide Drug
Products
56. Impurities at 0.10%- 0.5%
identified, characterized and
justified for not affecting the safety
and efficacy, including comparative
immunogenicity risk tests
Synthetic
Peptide Drug
Products
57. Medroxyprogesterone acetate â 1
injection for 3 months
Aripiprazole - 1 injection for 2
months
How do we understand safety?
Suspension for
Injections
Nano size,
insoluble, extended
release
60. RLD has two approved strengths:
500 mg and 750 mg
1. Approval for 1000 mg as generic
2. Approval for Biowaiver
Suitability
Petition
61. 1st is granted but 2nd is not
Although composition
proportionality in dissolution
supports
But
âą Drug product not shown to be highly
soluble and permeable
âą In-vivo evidence of dose
proportionality from innovator was
not performed
Suitability
Petition
62. âą Different route of administration
âą Different dosage form
âą Different strength
âą One API is substituted with other
API in a combination product
Suitability
Petition
Differences
considered