Many
pharmaceutical or biotechnological products require transport using
temperature-controlled systems to keep their therapeutic properties.
There are presently no official guidelines for testing pharmaceutical
products in order to define suitable transport specifications. After
reviewing the current guidance documents, this paper proposes a
methodology for testing pharmaceutical products and defining appropriate
transport conditions.
Key words: biotechnological products, distribution, pharmaceutical products, stability, temperature excursions, transport
INTRODUCTION
It
is considered good practice to test the stability of drug substances
and drug products according to the International Conference on
Harmonization (ICH) Q1A to Q1E (1–5), or Q5C (6)
guidelines, or the World Health Organization (WHO) Technical Report
Series, No. 953, 2009, Annex 2, “Stability testing of active
pharmaceutical ingredients and finished pharmaceutical products” (7).
In
a standard stability program, a stress study is first carried out to
determine the drug substance's degradation path and to establish
suitable analytical methods. Drug substance stability studies are then
conducted to define stability under long-term and accelerated storage
conditions. In the next phase of the development plan, the drug
substance is formulated into a drug product and compatibility of the
drug substance with excipients and container parts is then tested. When
suitable conditions are determined, long-term and accelerated studies
commence with the drug product. The data obtained from these studies are
used to define the optimal storage conditions and corresponding retest
dates for the drug substance or shelf-lives for drug product.
A
major concern of the pharmaceutical industry and health authorities is
to guarantee that drugs are delivered to patients without loss of
therapeutic properties. An ever-increasing number of therapeutic
products developed by the biotechnological or biologics (vaccines)
industries require temperature-controlled distribution channels, and it
is not infrequent that delays during transport put product quality at
risk when transport times and temperature control cannot be maintained.
In these cases, the drug may experience “temperature excursions”.
Products
sensitive to transport conditions need special care to ensure that
their quality is not impaired by transport operations. When talking
about sensitive products one usually thinks about products that are
sensitive to temperature, but other environmental conditions should also
be considered, including humidity, light, oxygen, shocks, pressure,
vibrations and X-rays encountered during shipment by truck, train, boat,
or plane.
Two points should be remembered before going
any further. The first is that regulatory authorities require that the
manufacturer ensures product quality not only during storage or
transport but until it is used for patient treatment: “The storage
conditions and the lengths of studies chosen should be sufficient to
cover storage, shipment, and subsequent use.” ICH Q1A 2.1.7 (1).
This requirement is a challenge for the manufacturer, since it must be
ensured even after controls by the manufacturer in the supply chain have
ended. This is usually the case when the product is sold to pharmacists
or hospitals for distribution to patients, and when patients store the
product at home.
The second point is that the drug
product manufacturer must decrease the risk of quality defects as much
as possible. Quality defects might occur either if the temperature
chosen for the transport of a temperature-sensitive product is outside
the registered storage temperature range, or if the transport
organization fails to maintain the planned transport conditions. Both
will increase the degradation of the product, so the manufacturer must
balance both situations and choose the best distribution plan. It might
be suitable to transport a product at room temperature if the studies
support this approach.
An additional, economic factor
should be considered. The value of a product ready to be used by the
patient has the highest cost along the whole supply chain. When a
product is ready to be used, its value not only includes the aggregate
cost of the drug substance, the drug product, storage and delivery, but
also R&D, marketing, sales, taxes and other items. If the product is
not properly stored during and after distribution, the loss can be
major. Failing to address the distribution channel correctly may have
negative consequences to patient health and harm the company's image, if
a recall is mandated. Profits may also be impacted by a lack of drug
availability.
There are no guidelines
(such as those on storage stabilities) for testing to determine the
suitability of transport conditions for sensitive products. After
reviewing the status of the leading pharmaceutical associations'
regulations and guidelines on transporting drugs, this paper will
describe test program for determining optimal transport conditions that
provide sufficient product protection, as well as satisfactory handling
and distribution.
REGULATIONS AND GUIDANCE
Significant
information on transporting medicinal products can be found in the
publications issued by the regulatory authorities and pharmaceutical
associations. This information is summarized below.
- ICH—WHO
ICH Q1A (2.1.2) (1)–WHO (2.1.2) (7)
gives general guidance on how to perform stress tests. The results of
such tests are essential to determine the sensitivity of a drug
substance to temperature, humidity, oxidation, pH and light. The results
of the stress tests are directly useful when it comes to transporting
the drug substance, and will help to determine appropriate tests to
control transport conditions for the drug product.
ICH
Q1A also describes the recommended conditions for performing long-term
and accelerated stability tests on drug substances and drug products
(see Fig. 1),
and gives useful guidelines on the temperature and humidity conditions
for running these tests. Advice is provided to manufacturers for using
these data:
- ICH Q1A; similar to WHO Glossary: Accelerated testing: “Studies designed to increase the rate of chemical degradation or physical change of a drug substance or drug product by using exaggerated storage conditions as part of the formal stability studies. Data from these studies, in addition to long-term stability studies, can be used to assess longer term chemical effects at non-accelerated conditions and to evaluate the effect of short term excursions outside the label storage conditions such as might occur during shipping. Results from accelerated testing studies are not always predictive of physical changes.”
- ICH Q1A chapter 2.1.7; similar to WHO 2.1.7: “Data from accelerated stability studies can be used to evaluate the effect of short term excursions higher or lower than the label storage conditions that may occur during the shipping of drug products.”
- ICH Q1A chapter 2.1.7.3; identical to WHO 2.1.7.3: Drug substances intended for storage in a freezer: “…testing on a single batch at an elevated temperature (e.g., 5°C±3°C or 25°C±2°C) for an appropriate time period should be conducted to address the effect of short term excursions outside the proposed label storage condition, e.g., during shipping or handling.”
- ICH Q1A chapter 2.2.7.5, similar to WHO 2.2.6.5:. Drug products intended for storage in a freezer “In the absence of an accelerated storage condition for drug products intended to be stored in a freezer, testing on a single batch at an elevated temperature (e.g., 5°C±3°C or 25°C±2°C) for an appropriate time period should be conducted to address the effect of short term excursions outside the proposed label storage condition.”
- ICH Q5C (6): Stability of Biotechnological/Biological Products section 6.3. Accelerated and Stress Conditions: “Studies under stress conditions may be useful in determining whether accidental exposures to conditions other than those proposed (e.g., during transportation) are deleterious to the product.”
From
these sections of the guidelines, it can be concluded that the
manufacturer can use the accelerated stability data to assess the
significance of temperature excursions outside the standard conditions
during transport.
- United States Pharmacopoeia
United States Pharmacopoeia (8)
has recently edited very interesting monographs on the programming of
stability tests. Interested readers can find valuable information in the
following documents:
- <795> Pharmaceutical Compounding—Nonsterile Preparations795>
- <797> Pharmaceutical Compounding—Sterile Preparations797>
- <1079> Good Storage and Shipping Practices1079>
- <1118> Monitoring Devices—Time, Temperature, and Humidity1118>
- <1191> Stability Considerations in Dispensing Practice1191>
- Parenteral Drug Association Technical Report 39, Revised 2007 (9)
is
certainly the best document to date for planning the testing of
products under temperature cycling conditions and evaluating the impact
of temperature excursions. Following the proposed tests, the
manufacturer can assess their product's sensitivity to temperature
variations such as those that occur during transport. The chosen
temperature should suit the specific situation.
- PDA Technical report 46, 2009 Last Mile: Guidance for Good Distribution Practices for Pharmaceutical Products to the End User (10)
provides practical guidance on how to transport products and includes a chapter on “stability data”.
The
FDA has presented their view that transport conditions may differ from
storage conditions, provided the manufacturer presents satisfactory
supporting data.
- Others
Bishara and Seevers (13,14)
have contributed significantly to the progress of the knowledge in this
field by setting preliminary standards that are now included in the
Parenteral Drug Association (PDA) documents. Temperature excursions and
temperature cycling conditions are proposed. As stated in the summary
“The effect of temperature excursions, outside of labeled storage
conditions, can be evaluated on the basis of the stability analysis for
that drug. Because the distribution environment is highly variable, a
stability program should be established that provides stability profiles
for each product. This article describes a stability program strategy
designed on the basis of the information provided by the development and
routine ICH Q1A stability programs.”
SETTING THE FRAMEWORK
Storage
conditions are defined during stability studies in accordance with the
ICH/WHO guidelines. However, a temperature-sensitive product may have
issues associated with its manufacturing and transport that are not
covered by the ICH/WHO conditions (see Fig. 1).
One clear example is the filling and packaging of frozen products.
According to the ICH/WHO, stability studies are limited to a −20°C
long-term study without accelerated conditions. But these products have
to be handled at temperatures which are not those of the long-term
storage conditions if they have to be thawed in order to be poured into
vials or syringes, or if they have to be brought to room temperature (or
at least above 0°C) to allow for proper labeling.
Additional
studies are necessary to complete the knowledge about a product's
stability profile. Such studies should include the time needed to
prepare the product (e.g., filling, labeling, packaging,
preparation for dispatch, transport, and receipt) and the consequences
of deviations during these operations.
Three different development areas can be distinguished:
- Studies on product storage (performed according to the ICH/WHO guidelines)
- Studies on product handling according to internal SOPs for filling, labeling, distribution
- Studies on managing unforeseen situations (e.g., that occur during distribution).
The
study plan will depend on the type of drug product. It has to consider
the parameters that are critical to prevent product degradation, and
should also evaluate the parameter limits within which the product can
be handled safely.
DIFFERENT TYPES OF PRODUCTS
The
stability program will depend largely on the product's sensitivity to
environmental conditions. The product should be understood as the
content AND the container, both of which determine final sensitivity.
Stable Products=products not sensitive to environmental changes (e.g., products that are heat sterilized after production)
- These products will usually be stored at 25°C, and no extensive studies are needed to define the transport conditions. The environment-related considerations should concentrate on finding conditions that preserve the products physical integrity.
Highly Sensitive Products=products
having a limited range of storage and transport conditions. Excursion
outside these ranges is an actual cause of product deterioration (e.g., vaccines that deteriorate when frozen).
- These products need extensive studies to assess the exact parameters in which the products keep their unique properties and those in which they are lost. In addition to tests relating to transport conditions, the testing program should embrace temperature, humidity (if not aqueous solutions), light, oxygen, shock, pressure and vibrations such as those experienced during transport and X-rays if transported by air (cf. airport security systems). They usually cannot be transported outside their long-term storage conditions.
Sensitive Products=products with a certain sensitivity to environmental conditions and that have to be protected during transport (e.g., most rDNA biotechnology products)
- These products need the same studies as the Sensitive Products to assess the exact conditions in which they maintain their unique properties and those in which they are degraded.
The
manufacturer can choose to transport the product within its storage
conditions and should study the effects of transport and possible
temperature excursions on the quality of the product until its delivery
and use by patients.
The manufacturer can also define transport conditions that are less sensitive to failure of transport operations (e.g.,
room temperature). If so documented, the product can be handled safely
outside its long-term storage conditions, provided the manufacturer has
satisfactory data supporting the handling/distribution conditions.
PARAMETERS TO BE TESTED DURING TRANSPORT TESTING
Drugs
can be sensitive to environmental conditions such as temperature,
humidity, light, oxygen, shock, pressure, vibrations, and X-rays. Drug
degradation depends on the value of the environmental conditions and the
period of time during which the product is kept at this value. For
small deviations from the storage conditions and short periods of time,
the consequences are usually not significant. Risk analysis will show
which tests should be planned (see Table I).
Temperature
is the main focus for testing because almost all pharmaceutical and
biotechnological products are sensitive to temperature. In addition,
transport in controlled conditions is not always reliable. There are a
number of problems that can arise:
- weather might follow unpredictable changes;
- customs procedures might take longer than anticipated;
- accidents might cause disruption;
- route used for transport might not be that anticipated;
- transport might stop at unsuitable places;
- temperature control systems might malfunction;
- communications between the various transport companies might have blocked the product (this could happen when the transport is contracted out to a chain of transport specialist such as shipper, forwarders, ground handlers/transportation service providers, consignee, air carrier);
- temperature sensors might be defective;
- information on the actual transport conditions might be inexact or lacking;
- other factors.
For
these reasons, the manufacturer should make the best possible efforts
to obtain formulation that is “stable” under a broad range of
conditions.
If this is not possible, the next objective
should be to assess extensively the limits in which the product can be
handled safely.
There are natural temperature ranges
that could be defined. It will be very unusual to have temperatures
below −100°C or over 100°C in a natural environment. In Antarctica,
temperature minima have been measured at −89°C. Temperature maxima have
been measured at +58°C in Libya and in Death Valley. But even if a
product is stored in a closed environment under the sun, it will not be
heated over 100°C.
Humidity during transport
is generally not critical due to the very short period of time when the
product is stored at high/low humidity. But humidity can change the
characteristics of solids or non-aqueous solutions which are packed in
non-tight containers. Preservation of a drug product at high or low
humidity is a testing condition of the ICH/WHO studies, and it is
usually not necessary to repeat/add this parameter to the
transport/distribution stability program.
Light is usually not a testing parameter, since products are shipped in light-resistant internal or external packaging.
Oxygen is usually not a testing parameter, since products are stored and transported in air tight containers.
A drop/rise in pressure
can damage products if packaging has not been tested for deformation or
leakage under high/low pressure. Blisters and sprays are examples of
sensitive packaging.
Some very interesting information is given in the IATA document (15):
“Normal, or standard, atmospheric pressure at sea level is usually defined at … 1013 millibars; however this number varies greatly due to the weather.Generally speaking, cargo compartments on cargo and passenger aircraft are pressurized to the same levels. The pressure in the each aircraft varies during flight, depending on altitude and pressurization settings. Normally, the pressure varies from sea level pressure of 1013 millibars to a value no less than 800 millibars, ….It should be noted that ‘feeder aircraft’ are not subject to the same pressure situations. These trips are potentially non–pressurized and used to transport express air packages to remote areas. In this case, cargo experiences the same ambient pressure as the pilot.”
ISTA (15) or ASTM (16) propose standard tests for the vibration, shock, and atmospheric conditioning.
Vibrations
might damage solid dosage forms during transport if they are friable.
Vibrations have also been shown to increase the appearance of particles
in protein-containing solutions and to influence their therapeutic
properties. For sensitive pharmaceutical or biotechnological products,
this is certainly a parameter that has to be evaluated.
Shocks
can damage products if packaging has not been tested for shock
resistance. Shock might damage solid dosage forms during transport if
they are friable.
Radiation can be an issue
for biologic products and those that have been shown to be sensitive to
X-rays during tests using this method of sterilization.
The International Air Transport Association (IATA) document has the following information (17):
17.13.2 Radio Frequency (RF)Most pharmaceutical products are exposed to RF energy throughout the supply chain. RF is used as a tool for inventory purposes as well as supply chain visibility. This low energy is considered to be benign. However the FDA has requested that pharmaceutical companies perform RF energy input studies for their Biologics (this is not necessary for non–biologics) to see if there is any modification to the biologic that is not typical of heat degradation.17.13.3 X-ray (radiation exposure in airplanes and at airports)Pharmaceutical products can be exposed to X-rays (man induced and or naturally occurring) throughout the supply chain. Generally speaking, the amount of X-rays that a product can be exposed to at an airport during screening is significantly less than what the exposure would be in the cargo hull at 35000 ft. If a product is known to be sensitive to X-ray energies, the manufacturer should work with the broker and customs to not have product X-rayed at the exit and entree ports and work with the airline to take appropriate precautions during air travel. Extra shielding might be an appropriate means of protection against this radiation ….
STABILITY STRATEGY
The
stability manager has to define what the scope of the transport and
distribution studies should be and when to carry them out. This
information will be used to develop a stability plan.
When to Run a Stability Test to Assess the Distribution Conditions?
The
stability studies covering the company's transport and distribution
requirements have to be planned at the right moment as part of the
overall development plan. If they are planned too early, they might be
invalid if the formulation, the container or the distribution plans are
revised, and will then have to be repeated.
In the
early phase of the development plan, the manufacturer wants to guarantee
that the product is compliant with the requirements for all preclinical
and clinical studies. If there is insufficient data, the manufacturer
will be forced to use transport and distribution conditions known to be
protective for the product; typically, these include liquid nitrogen,
dry ice, −20°C or any other conditions where product stability has been
demonstrated during the necessary time period.
Stability
studies for a product's transport and distribution are reasonably run
with the stability of a product prepared for pivotal phase-3 clinical
trials. At this product development stage, the manufacturer has already
accumulated preliminary stability data, providing an indication of
appropriate storage and distribution conditions. These have to be
challenged, since the process/formulation/packaging/etc. might have been changed before starting phase-3 clinical trials.
Scope
The
next point to examine is the scope of the study. The proposed tests
should be related to production environment and distribution channels.
This can be challenging, since typically at the beginning of the phase-3
clinical trials, the manufacturer often has only a very vague idea of
what the marketing and related production and distribution activities
will actually be after registration, and later during its
commercialization.
Knowing the product's sensitivity to
the parameters of concern is the first objective of the study. The
correspondence between this sensitivity and the required minimum needs
for distribution and subsequent use by customers/patients will determine
the product distribution conditions.
The basic scope of the stability study is to define the transport conditions as proposed in Table II.
Having
limited understanding of the product's properties at this point in the
development lifecycle means that it might require considerable effort to
focus on the right testing conditions that are not too drastic (where
the product deteriorates too much) or too mild (where the product does
not deteriorate and therefore could stand additional stress). Using a
mathematical model could help to assess the temperature excursion effect
on the product's potency (18). The basic scope can be translated in an alternative scope as described in the Table III.
When the scope is clearly defined and approved, it is time to program the studies.
Program the Study
The proposed analytical strategy for programming the studies on transport stability is described in Table IV.
Limits of the Study
The
stability manager should start by evaluating the range of
investigations appropriate for the product under consideration. Is the
drug substance already present in another drug product? Is the product a
well-known type of product in the company? What are the relevant
experiences available for the present product? What are the parameters
that impact the quality characteristics? What are the limits of these
parameters? Are they limited on both sides by maximum/minimum values?
Are there intermediate values that could be relevant? Is it a
multidimensional study? Are there potential dependent parameters? What
are the limits for the investigations?
Stress Studies
At
the beginning of a drug substance's development, manufacturers conduct
stress tests to determine its sensitivity to different environmental
conditions. They usually choose temperature, humidity, light, and oxygen
as stress factors and push the studies conditions up to when
degradation paths are activated and detected. These tests will show two
main correlated factors:
- the value of analytical methods for detecting product degradation;
- the nature of the degradation paths.
In Fig. 2,
the drug substance has been placed at 50°C for 3 and 7 days. It can be
seen on the HPLC traces after 3 days that two degradation peaks are
built before and after the main peak and that these peaks increase after
7 days.
Degradation study: example of HPLC traces after 3 and 7 days at +50°C, compared with the initial data
It
is of utmost importance to determine the toxicity of degradation
byproducts. Are they much more toxic than the drug substance, or is
their toxicity close to or less than the substance? The answers to these
questions are needed to determine the specifications of the drug
substance and later of the drug product.
The results
of these studies give direct indications for transporting drug
substances, showing whether special precautions should be defined or if
ambient conditions are satisfactory.
For
drug products, the results of stress studies are usually not directly
interpretable, with the exception of the products that are similar to
the drug substance, since the presence of excipients should modify the
intrinsic properties of a drug substance in a positive way. The main
focus should be an understanding of the degradation pathways and of the
corresponding detection methods. This knowledge can be used to build
formulations that are able to protect the product from degradation.
Additionally, it will help the manufacturer to define the testing
program for the transport conditions.
Supportive Accelerated/Long-term Studies
Supportive
accelerated/long-term stability studies show the consequences of
temperature on a drug product. It would be a great help to have the
ICH/WHO stability studies results from early development batches, or
other supportive data, since this could make it possible to model
product stability. For liquid products, using the long-term and
accelerated data can help determine the Arrhenius pre-exponential A and Activation Enthalpy dHa
parameters. Based on these, a mathematical simulation of the product
degradation can be run showing the product stability performances (18).
Distribution Channels
With
these initial data, based on the available experience the stability
manager and the distribution manager can study the best routes/transport
conditions for distributing the product, from initial product storage
down to patient administration. They will study the answers to questions
such as: “Which is the best option for the packaging? Is a
thermostatized pack better that a thermostatic container filled with
standard boxes? Which road to follow? If the product has to be stored in
a freezer, how can it be handled for filling and labeling?”
Different
situations for the handling of medicinal products when packed in their
final container need to be considered, as illustrated in Table V for a product to be stored under refrigeration.
In
the previous example, the conditions for formulation, filling and
intermediate storage should be studied independently, since the
packaging of bulk product is not the same as drug product.
Safety Margin
The
next question pertains to the risk attaching to the distribution
channel. What to do in the worst case? How long could the transport
last? At what temperature? How long could the user store the product? At
what temperature? Knowing all this makes it possible to define the
safety margin.
The safety margin will depend on the
type of product (a solid might be less sensitive to unexpected
degradation than a liquid, due to the speed of reactions in solid phase versus liquid phase).
The
safety margin should also take into account the uncertainty regarding
the tests results, (assessing the error on the temperature/testing
method/time) and the company's risk policy.
The safety margin could be in different forms:
- Percentage of time (set the official limit at x% of real experimental time when degradation is observed);
- Percentage of product (set the official limit at y% of the real experimental quantity where toxicity is observed).
The
safety margin might also be dependent on the number of experiments
available; the first batch placed in stability will not provide as much
confidence as the tenth. The margin might be modified over time as
experience grows.
Stability Plan
Once
these preparatory steps are finished, the stability plan can be
written. Note that the ICH/WHO long-term and accelerated stability
conditions start with a 1-month testing timeframe. This period is not
adapted to handling operations.
Knowing the projected
properties of the product and the anticipated distribution channels, the
stability manager will be able to write a plan demonstrating that the
studies correctly supports the distribution channels and also adequately
supports deviations that could occur during the product's transport.
Different types of studies are suitable for defining product's sensitivity to distribution.
- Temperature excursion studies and cycling studies (e.g., PDA technical report 39 (19)).
- Freeze-thaw studies are another type of study that can be valuable for biologics or biotechnological products since their structure might be changed by freezing/thawing conditions. Presence of particles has also been observed after such temperature variations.
- Real time studies such as those performed with a temperature program simulating the real transport conditions e.g., during summer and winter times are best suited when the manufacturer knows quite accurately what are the distribution channels.
Additional Tests for Transport
Testing
required to assess transport effects on the product should be
distinguished from tests aiming to evaluate the effect of temperature
excursions outside the stated temperature ranges.
The
manufacturer defines transport conditions based on the available data
from his experience. Having performed a risk analysis, he defines the
transport conditions guaranteeing that product quality meets the
requirements when the product is used by the patient as prescribed. This
is usually referenced in a table such as the one presented in Table VI.
Tests such as those described by the PDA (9) document under temperature cycling or in the article of Bishara (14) are examples that can be indicative for the manufacturer looking for a set of conditions to be followed.
If
the chosen transport temperature differs from the long-term storage
temperature, the conditions must be fully tested and shown to be
suitable for the desired purpose. To reach this goal, it might be
necessary to conduct tests to assess the suitability of transporting the
product at a controlled temperature. The simplest situation is when
products are transported between two sites such as manufacturing and
distribution sites; in this case, manufacturers can simulate transport
conditions knowing time and transport roads and using meteorological
extremes between the starting and recipient locations. Classical studies
use two profiles, one simulating winter conditions and one simulating
summer conditions. Product is placed in the chosen transport container
during a period of time corresponding to the longest anticipated
transport duration. Temperature is cycled at values simulating daily and
night external temperatures as they have been measured during previous
transports or recovered from meteorological historical data.
A
special situation occurs when the starting location is in the Northern
hemisphere and the receipt location in the Southern hemisphere or the
reverse. In this case, mixed testing conditions should be used,
simulating the actual seasonal conditions at the starting and recipient
locations. These types of profiles are called summer-winter or
winter-summer profiles (see Fig. 3).
When
the profiles are defined, the product packed in its transport box is
tested for a defined period in these conditions. The product temperature
should remain within the specified limits at all times.
The
other situation is represented by transport of products from a
distribution center to many uncontrolled recipient locations. In this
case, there is no real model and it is the responsibility of the
manufacturer to ensure that the instructions given to the distribution
channel are clear enough to ensure the quality of the product. Stability
tests as described above and other tests are to be used as described
below.
Additional tests should be considered when risks related to the vibrations or radiations are identified. ISTA (15) or ASTM (16) propose standard tests for vibrations, shocks and atmospheric conditioning.
These
tests should simulate as closely as possible the projected transport
scheme. But it is important to have a long-term vision to extend the
transport schemes to new distribution channels, as marketing will boost
sales.
Additional Tests for Temperature Excursions
Tests
to assess the consequences of temperature excursions are different in
that they are carried out to check the effects of additional stress on
the product, such as those resulting from a dramatic situation outside
the standard conditions.
Preparing them is difficult,
since no one knows what will happen in the next deviation situation.
Some suggestions are to consider the MKT approach and to evaluate the
range where the product can keep its properties when stressed by
temperature excursions. The MKT is an indirect approach as it gives an
evaluation of the temperature supported by the product, which is not a
representation of the stress supported by the product; it gives no
information allowing the person in charge to evaluate the consequences
of the deviation.
Another approach is to use a
mathematical evaluation of the product degradation during the
temperature excursion as recently described (18).
This paper presents a mathematical approach to dealing with temperature
excursions. It is based on existing tools, such as the Arrhenius
equation and the first-order kinetic equation. The aim is to help the
Qualified Person (QP) decide whether to release a product that has
experienced a temperature excursion. The available stability data are
worked out and completed with additional short tests. This evaluation
makes it possible to determine the potential degradation that has
occurred during the temperature excursion.
If
this approach is not practicable, the standard development methods,
Design of Experiment (DoE) or “Trial and Error” approach based on the
available experience can be used. Some guess studies such as
“Temperature Excursions” can help the manufacturer to identify possible
limits and respond to temperature deviations.
Combination Studies
A
related question is the need for combination studies. Each stress
condition imposed on the product will increase the degradation
mechanisms that affect its quality. Some of these will have a negligible
effect, but others will have significant consequences. For example, if
the product is subject to transport outside its storage conditions, it
is important to ensure that the expiry date as determined during
long-term studies remains valid. Studies with this aim are best run as
combination studies, where the product is subjected to transport
conditions e.g., at the beginning, middle and/or end of long-term stability studies.
Similarly,
temperature excursions studies should be performed at different time
points of the long-term study, to simulate the real-life conditions.
Scheduling the Studies for Storage, Transport and Temperature Excursions
Having
a comprehensive view of the activities to be carried out will help the
stability manager to be more efficient. Studies can be scheduled
logically, considering the number of samples to be placed in different
conditions and the time when the analysis will be performed. There are
excellent reviews on this activity elsewhere (19)
The best plan is to run the studies in two phases:
- The first phase consists of assessing short-time sensitivity (up to one month) and establishes if the initial estimate was within the target range.
- The second phase is to run the full set of tests, taking into account the findings of the first phase.
Building stability knowledge or having a clear vision of the stability properties
For Product Distribution
How to interpret the available stability data?
The
goal is to assure patients and health authorities that the manufacturer
can control product quality until use. To achieve this goal, the
manufacturer should build knowledge and understand how to control
product degradation or conversely to understand the reasons underlying
the presence of an unacceptable amount of degradation products.
He
should first determine what is the acceptable amount of degradation
products and in what conditions they will be formed. As described above,
temperature is the most important parameter for most of the sensitive
products.
The main information is the temperature/time
relationship and the manufacturer will find out that certain periods of
time are more relevant than others (see Table III).
Fixing the standard operational times will decrease the number of
observations to the minimal amount. For example, it is difficult to
handle a medicinal product in less than 1 h. Handling a batch of
thousands of units (e.g., taking it out of the storage room,
preparing dispatch, loading a truck) lasts at least this period of time.
Labeling this same batch on an automatic machine will last one shift or
more. Transporting a batch from one manufacturing site to a
distribution site abroad might last a couple of days.
It
is now time to determine the temperature limit at which the product can
be placed until it is degraded at the acceptable value. This can be
done by using the mathematical model described in Ref. (18).
At the beginning of product development, knowledge is scarce and the picture is all dark gray (see Fig. 4a).
Defining the theoretical upper limit of product stability, using the
mathematical model presented elsewhere will be of great value and will
allow the manufacturer to better understand the product. The data from
early stability tests will be valuable to plan the initial evaluations.
If in addition, the manufacturer defines the safety margins that apply
to the product, the range in which the product can be handled safely can
be clearly defined (see Fig. 4b).
Example showing how to build stability knowledge. a At the beginning. b With the preliminary mathematical model and safety margin. c With the ICH/WHO stability program. d With the preparation/distribution plan. e With a full set of tests
The ICH/WHO stability data guidelines define appropriate temperature ranges for the different study ranges −20°C±5°C, +5°C±3°C, 25°C±2°C, 30°C±2°C, 40°C±2°C (see Fig. 4c).
The manufacturer will have a better view within the tested ranges and
find how to organize the manufacturing and transport operations (see
Fig. 4d). But there will still be a lack of information outside these ranges.
Additional
studies should focus on clarifying the ranges in which the manufacturer
needs information to deal with transport and temperature excursions
(see Fig. 4e). Using standard periods of time (see Table III)
the manufacturer will determine the parameters of the tests to be
conducted. The product will be placed at the upper temperature of each
range and tested for degradation during the time that has been
determined. If the degradation's value is at or below the limit, the
manufacturer can reasonably fix the limits for accepting a temperature
deviation. Obviously, all stability-determining parameters must be
evaluated.
This is how manufacturer can build his stability knowledge.
When
this set of analysis is complete, the final version has to be settled
and will be useful for temperature excursion investigations.
For Temperature Excursion
This
same representation can be useful for decisions relating to temperature
excursions. The information is reported directly on the product
temperature profile. The decisions that have to be taken are supported
by real data.
In the example below, one batch of product has been stored at 34°C for 8 h (see Fig. 5a).
The person in charge can report this value in the table and show that
the quality of the product is still within the accepted values of the
parameter tested. In the second example, one batch has been stored for
10 days at 34°C (see Fig. 5b).
Here it is clear that the quality of the product is endangered by this
temperature excursion. The other tests parameters which are relevant for
stability studies still have to be evaluated before releasing or
rejecting the batch.
FINAL CONSIDERATIONS
After all the tests have been performed and evaluated, the company will obtain a table similar to Table VI.
These
are the specifications that are supported by the data and include the
safety margin. They show the authorities that the manufacturer has
adequate control of the product stability profile that will be included
in the application for marketing approval.
These
values must be restrictively provided to persons who have a limited view
of the full batch history and are unaware of the product properties.
This will prevent the uncontrolled risk that a stakeholder or patient
takes a wrong decision based on his partial and incomplete knowledge.
The labeling should be clear, and a proposal has been provided by the IATA (15) in its regulation e.g., see Fig. 6.
By
keeping track of the handling conditions and by summing the time at
each temperature, the manufacturer can assess whether the batch is
acceptable for use by the patient.
Temperature
excursions are examined in the light of the available data set. If a
mathematical model has been developed, it can assist evaluation of the
consequences on the criticality of the excursion.
CONCLUSION
The
manufacturer must ensure that products delivered to patients comply
with the marketing authorization. For products sensitive to transport
conditions, this means that the manufacturer has to control the product
stability profile and choose the correct storage conditions and
appropriate transport systems. When the transport conditions deviate
from the specified values, there is a sound basis to decide whether to
release or to reject the batches.
The storage conditions are best determined in accordance with the ICH/WHO stability testing programs.
Transport
conditions have to be determined considering the risks of product
degradation. If the product is very sensitive to one or more parameters,
the manufacturer has little margin to set the transport conditions.
Tight limits, identical or close to those of the storage conditions,
will be required. On the other hand, if the product is somewhat
resistant to extended parameters for a short period of time, it is in
the interest of the manufacturer and the users to have extended
transport conditions. In the example of a refrigerated product, the
chosen transport conditions could be “room temperature” or “controlled
room temperature”, allowing the product to be transported in conditions
that are not too difficult to guarantee for the many transport
operations that are necessary to reach the patients. The risks of
deviations are diminished, without increasing the risk to the patients.
The
preliminary information needed to optimize transport conditions is
knowledge about product sensitivity to the relevant transport
parameters. Tests in addition to those proposed by the ICH/WHO
guidelines should be planned to complete the picture.
Acknowledgment
The
author would like to acknowledge Dr. Manuel Zahn, Managing Director, 3R
Pharma Consulting GmbH, Dr Steve Butcher and Dr Eugene Helsel, Senior
Director, Quality, Stemedica Cell Technologies, Inc., San Diego, CA, for
reviewing the article and their very appreciated and friendly support.
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