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Process Analytical Technology Concepts and Principles

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<strong>Process</strong> <strong>Analytical</strong><br />

<strong>Technology</strong><br />

<strong>Concepts</strong> <strong>and</strong> <strong>Principles</strong><br />

Mark L. Balboni<br />

<strong>Process</strong> analytical technologies are a<br />

multifaceted group of concepts that<br />

comprise one of many initiatives that form<br />

FDA’s “Pharmaceutical GMPs for the 21st<br />

Century.”Yet what constitutes a process<br />

analytical technology or whether it is in fact<br />

a new technology remains unclear. This<br />

article outlines the key concepts that define<br />

process analytical technology <strong>and</strong><br />

emphasizes the relevant theory <strong>and</strong><br />

applications of chemometrics.<br />

PHOTODISC, INC.<br />

Mark L. Balboni is a senior compliance<br />

consultant at KMI, a division of PAREXEL<br />

International, LLC, 28241 Crown Valley<br />

Parkway, F601, Laguna Niguel, CA 92677,<br />

tel/fax 949.830.2355, mbalboni@belmont.<br />

kminc.com.<br />

The current process analytical technology (PAT) initiative<br />

underway within FDA exemplifies the latest consortium<br />

between FDA <strong>and</strong> the industry that aims to encourage<br />

the concepts of quality by design, use of computerized<br />

data gathering <strong>and</strong> evaluation techniques, <strong>and</strong> process- <strong>and</strong><br />

product-monitoring methods through advanced instrumentation<br />

<strong>and</strong> data evaluation. Although this partnership between<br />

FDA <strong>and</strong> the industry is relatively new (2001), methods related<br />

to PAT such as chemometrics have been studied <strong>and</strong> have been<br />

in use for quite some time. Yet, the PAT initiative has raised several<br />

questions: What does PAT really encompass? Is it a new<br />

technology or is it a series of proven scientific principles? How<br />

can PAT be used in a pharmaceutical operation to gain better<br />

process underst<strong>and</strong>ing <strong>and</strong> possibly reduce cycle times <strong>and</strong> associated<br />

costs?<br />

This article discusses the concepts that embody PAT. Emphasis<br />

is placed on chemometrics, which is the use of mathematical<br />

<strong>and</strong> statistical models to extract <strong>and</strong> interpret chemical<br />

data.<br />

What is PAT?<br />

FDA defines PAT as<br />

● a system for the analysis <strong>and</strong> control of manufacturing<br />

processes based on timely measurements of critical quality<br />

parameters <strong>and</strong> performance attributes of raw materials <strong>and</strong><br />

in-process materials<br />

● a process to ensure acceptable end-product quality at the completion<br />

of the processing (1).<br />

FDA also states that PAT involves<br />

● the optimal application of process analytical chemistry (PAC)<br />

tools<br />

● feedback process-control strategies<br />

● information management tools <strong>and</strong>/or product–process optimization<br />

strategies for the manufacture of pharmaceuticals<br />

(1).<br />

In summary, PAT can be defined as the optimal application of<br />

PAC tools, feedback process-control strategies, information<br />

management tools, <strong>and</strong>/or product–process optimization strategies<br />

to the manufacture of pharmaceuticals.<br />

PAT focuses on the principles of building quality into the<br />

product <strong>and</strong> process as well as continuous process improvement.<br />

A few examples of PAT tools <strong>and</strong> strategies are as follows:<br />

54 Pharmaceutical <strong>Technology</strong> OCTOBER 2003 www.pharmtech.com


● at-line, in-line, or on-line measurement of process quality<br />

<strong>and</strong> performance attributes using a variety of instrumentation<br />

<strong>and</strong> measurement strategies such as near-infrared (NIR),<br />

vibrational, acoustical, <strong>and</strong> X-ray spectroscopy<br />

● chemometric approaches such as multivariate statistical <strong>and</strong><br />

pattern recognition methods.<br />

● real-time data <strong>and</strong> information management systems for<br />

process control (2).<br />

FDA’s PAT initiative is supported by many large pharmaceutical<br />

corporations <strong>and</strong> distinguished members of academia.<br />

Another potential advantage of PAT is the opportunity to<br />

place more reliance on in-process testing as the basis for final<br />

product release. This type of product-release methodology requires<br />

both a significant amount of data to be compiled <strong>and</strong><br />

heavy correlations to be determined by analysis <strong>and</strong> evaluation<br />

(3). The theory is that product release could be based on relationships<br />

(i.e., correlations between observed in-process test results<br />

<strong>and</strong> predictive qualitative results of the final product) established<br />

during product–process development <strong>and</strong> confirmed<br />

by both validation <strong>and</strong> routine review of product–process data<br />

for commercial lots. These relationships coupled with confirmation<br />

testing of the finished product would serve as the basis<br />

for release, or the product could possibly be released on the<br />

basis of the observed in-process results <strong>and</strong> how a currently<br />

produced lot favorably compares with other previously released<br />

product lots.<br />

FDA’s PAT initiative is being spearheaded by the Center for<br />

Drug Evaluation <strong>and</strong> Research (CDER), Office of Pharmaceutical<br />

Science. Since 2001, FDA has held <strong>and</strong> participated in a series<br />

of PAT meetings as part of the <strong>Process</strong> <strong>Analytical</strong> Technologies<br />

Subcommittee for the Office of Pharmaceutical Sciences<br />

<strong>and</strong> with the FDA Science Board. These meetings have included<br />

not only FDA personnel but also pharmaceutical industry representatives,<br />

members of academia, <strong>and</strong> engineering <strong>and</strong> consulting<br />

professionals.<br />

The PAT initiative is part of a larger FDA initiative called<br />

“Pharmaceutical CGMPs for the 21st Century: A Risk-Based<br />

Approach”(4). The agency seeks to improve the regulation of<br />

pharmaceutical manufacturing using a science- <strong>and</strong> risk-based<br />

approach to product-quality regulation while incorporating an<br />

integrated quality-systems approach.<br />

Complete descriptions of FDA’s PAT initiative <strong>and</strong> the “Pharmaceutical<br />

CGMPs for the 21st Century” approach, including<br />

electronic links to associated documents <strong>and</strong> reference materials,<br />

are provided in References 1 <strong>and</strong> 4.<br />

PAC <strong>and</strong> in/at/on-line monitoring<br />

According to Hailey et al., PAC is the technique of “gathering<br />

analytical information in real time at the point of manufacture”<br />

(5). As they noted, PAC “places an emphasis on the process<br />

rather than the final product,” including “an underst<strong>and</strong>ing of<br />

the relationship between final product specification [sic] <strong>and</strong><br />

the critical variables during the manufacturing process.”<br />

Although the approaches <strong>and</strong> instrumentation currently<br />

being discussed are in some cases categorized as being novel or<br />

new, real-time measurement (PAC) has existed for some time<br />

(e.g., real-time temperature monitoring of reaction vessels during<br />

the synthesis of active pharmaceutical ingredients). One<br />

particular industry–university partnership, The Center for<br />

<strong>Process</strong> <strong>Analytical</strong> Chemistry (CPAC) at the University of Washington,<br />

has been in existence since at least 1986 (6).<br />

Although PAC is not a new approach, many of the related<br />

techniques have been tested <strong>and</strong> used only on a limited basis<br />

by a very small percentage of the pharmaceutical industry. The<br />

following is a partial list of the various sensors <strong>and</strong> instrumentation<br />

recently discussed at the 2003 Arden House Conference<br />

either in-use or currently being evaluated for feasible use for<br />

production monitoring:<br />

● NIR spectroscopy for moisture determination<br />

● X-ray spectroscopy<br />

● radio frequency for moisture determination<br />

● microwaves for moisture determination<br />

● RAMAN spectroscopy, with vibrational spectroscopy being<br />

the most common. RAMAN complements IR spectroscopy<br />

<strong>and</strong> is used for raw-material identification, polymorph differentiation,<br />

<strong>and</strong> reaction monitoring.<br />

● fluorescence for water quality<br />

● on-line measurement of color<br />

● X-ray fluorescence for the detection of inorganic materials<br />

● photoacoustic spectroscopy.<br />

Because most of these technologies are extremely sophisticated,<br />

one must realize that the key emphasis of PAT is not so<br />

much how to collect the data or what kind of instrumentation<br />

should be used, but rather what data should be collected, what<br />

is done with these data, <strong>and</strong> what associated conclusions are<br />

reached. Therefore, a complete <strong>and</strong> thorough underst<strong>and</strong>ing of<br />

the manufacturing process is paramount.<br />

Chemometrics<br />

To fully underst<strong>and</strong> PAT, one must first underst<strong>and</strong> the science<br />

behind manufacturing processes, including how these processes<br />

operate, their limitations, <strong>and</strong> their expected outcomes.<br />

In 1974 Sante Wold, from the Institute of Chemistry at Umea<br />

University (Umea, Sweden) described “the art of extracting<br />

chemically relevant information from data provided in chemical<br />

experiments” as chemometrics (7). He stated that this art is<br />

“heavily dependent on the use of different kinds of mathematical<br />

models” <strong>and</strong> that it was important to have knowledge in<br />

statistics, numerical analysis, <strong>and</strong> applied mathematics, including<br />

the challenge to “structure the chemical problem to a form that<br />

can be expressed in a mathematical relation.”<br />

Twenty years later, during a 1994 presentation, Professor Wold<br />

said his definition of chemometrics had not changed much. He<br />

said chemometrics requires us to ask ourselves “How do we get<br />

chemically relevant information out of measured chemical data;<br />

how do we represent <strong>and</strong> display this information; <strong>and</strong>, how do<br />

we get such information into data?”<br />

In 1996, Wise <strong>and</strong> Gallagher stated chemometrics “is the science<br />

of relating measurements made on a chemical system to<br />

the state of the system via application of mathematical or statistical<br />

methods” (8). Similarly, Hardy noted that data are “raw<br />

information, both qualitative <strong>and</strong> quantitative” (9). He observed<br />

that in <strong>and</strong> of themselves, “raw data are meaningless” <strong>and</strong> that<br />

a method of “analysis <strong>and</strong> a model” are needed to “gain knowl-<br />

56 Pharmaceutical <strong>Technology</strong> OCTOBER 2003 www.pharmtech.com


edge” from the data. He also identified the clear need for a<br />

process to “convert data to knowledge.”<br />

Dosage forms recently have been described as “complex<br />

multifactorial physiochemical systems” (10), sometimes referred<br />

to as multivariate. Multivariate analysis “consists of<br />

methods of statistical analysis of multivariate data, characterized<br />

as consisting of several observations on each set of objects<br />

or mathematically represented by a collection of points<br />

in a finite-dimensional Euclidean space R P ” (11). So, multivariate<br />

analysis is an important statistical method widely used<br />

by chemometricians.<br />

Described below are a few of the tools commonly used by<br />

chemometricians, all of which are helpful for evaluating processing<br />

data generated during pharmaceutical unit operations<br />

or when synthesizing active pharmaceutical ingredients.<br />

Principle component analysis (PCA). PCA is a technique used to<br />

express variations of many variables by a small number of indicies<br />

(11). Wise <strong>and</strong> Gallagher describe PCA as a favorite tool<br />

of chemometricians for data compression <strong>and</strong> information extraction<br />

<strong>and</strong> note that “PCA finds combinations of variables or<br />

factors that describe major trends in a data set” (8). Sans et al.<br />

(12) observed that PCA can be used to determine the number<br />

of components that influence the data of the process as well as<br />

to identify the chemical meaning of the components. They proposed<br />

that PCA enables one “to approach multivariate chemical<br />

problems in order to obtain underlying information about<br />

the correlation of the raw data <strong>and</strong> the real meaning interpretation.”<br />

Finally, Wise <strong>and</strong> Gallagher (8) acknowledged that “generally<br />

there is a great deal of correlated or redundant information<br />

in process measurements,” <strong>and</strong> “often essential information<br />

lies not in any individual process variable but how the variables<br />

change with respect to one another” or how they co-vary. They<br />

also noted that “some sort of signal averaging” would be useful<br />

in cases in which a large amount of noise is created from the<br />

volume of data <strong>and</strong> a lack of clear underst<strong>and</strong>ing of the data<br />

exists.<br />

However, Wu et al. point out two limitations of PCA:<br />

● When an object is added or removed as displayed in a plane,<br />

principal components (PCs) must be recalculated all over<br />

again by following the process of selection <strong>and</strong> interpretation<br />

of the PCs.<br />

● No more than two PCs at a time can be viewed (inspected)<br />

in a plane, <strong>and</strong> this prevents one from using the information<br />

contained in other PCs (13).<br />

The authors also note that their “star-plot” method could be<br />

used as an alternative way to display <strong>and</strong> analyze multivariate<br />

data.<br />

Application of PCA to chemical processes. Wise <strong>and</strong> Gallagher (8)<br />

studied data obtained from a slurry-fed ceramic reactor using<br />

thermocouples placed at 20 locations (8). They found a great<br />

deal of correlation as the data generated followed a sawtooth<br />

pattern. In addition, the study revealed the following:<br />

● PCA performed on this data found three factors that captured<br />

approximately 97% of the variance in the data set.<br />

● This previously noted finding allowed 16 variables to be replaced<br />

with three new ones, which were linear combinations<br />

of the original variables.<br />

● The sawtooth pattern was attributed to changes in the level<br />

of molten glass, which was a controlled variable.<br />

● The three factors (PCs) were identified as the level of molten<br />

glass in the reactor, the variation between two groups of measured<br />

locations, <strong>and</strong> the variation of overall process temperature<br />

(also a controlled variable).<br />

Sans et al. also used PCA to determine stoichiometric models<br />

from on-line spectroscopy for selecting the number of reactions<br />

<strong>and</strong> the number of chemical absorbing species to better<br />

describe a chemical reaction (12). They chose to use<br />

spectroscopy methods because they can reveal information<br />

about the dynamic evolution of the reaction mass during a<br />

chemical reaction. Although the outcome of this study is not<br />

discussed in this article, Sans et al. did note that “semibatch<br />

processes are examples of complex reaction networks that generally<br />

are difficult to interpret because of the large number of<br />

reactions occurring simultaneously <strong>and</strong> because of the effects<br />

related to the addition of materials that may cause complex volume<br />

changes during the processing time.”<br />

Multiway principle component analysis (MPCA). An analog of PCA<br />

is what is known as multiway PCA, which is “equivalent to performing<br />

PCA on a very large two-dimensional matrix formed by<br />

unfolding the three-way array X into one of six possible ways,<br />

only three of which are mathematically unique” (8). General PCA<br />

methods do not take into account the ordered nature of the data<br />

sets, meaning that the data were not collected in a sequential<br />

manner. Multiway methods take into account the ordered (sequential)<br />

nature regarding when data were generated “because<br />

the data usually are organized into time-ordered blocks that are<br />

each representative of a single sample or process run” (8).<br />

Nomikos <strong>and</strong> MacGregor (14) describe another aspect of<br />

MPCA; namely, the use of on-line measurements to identify<br />

“significant deviations from the normal operating behavior by<br />

using SPC charts.” An empirical model is based on data generated<br />

when the process is operating within a state of control.<br />

They noted, “future unusual events are detected by referencing<br />

the measured process behavior against the ‘in-control’ model<br />

<strong>and</strong> its statistical properties.”<br />

Partial least squares (PLS). Wise <strong>and</strong> Gallagher described PLS<br />

as a regression “related to both principle component regression<br />

(regression of properties on the principle component scores of<br />

the measured variable) <strong>and</strong> multiple linear regression (also<br />

known as inverse least squares)” (8). They observed that this<br />

analysis can be used to predict “properties of a system based on<br />

variables that are only indirectly related to the property.” Accordingly,<br />

by using PLS, one attempts to “find factors” that both<br />

“capture variation <strong>and</strong> achieve correlation.”<br />

Multiway partial least squares (MPLS). Nomikos <strong>and</strong> MacGregor<br />

observed that MPCA using statistical process-control charts<br />

“only makes use of the process variable trajectory measurements<br />

(X) taken throughout the duration of the batch” (14). In contrast,“multiway<br />

partial least squares (MPLS) can be performed<br />

using both the process data (X) <strong>and</strong> the product quality data<br />

(Y),” <strong>and</strong> “focuses more on the variance of X that is more predictive<br />

for the product quality Y” (14).<br />

Other statistical tools. Two other statistical tools that may be<br />

useful in PAT efforts are<br />

58 Pharmaceutical <strong>Technology</strong> OCTOBER 2003 www.pharmtech.com


● capability studies, which measure the ability of the process to<br />

consistently meet specifications by evaluating select process<br />

outputs <strong>and</strong> calculating the average <strong>and</strong> ranges over a specified<br />

time on control charts. From these studies, capability indicies<br />

Cp (used to evaluate the variation) <strong>and</strong> Cpk (used to<br />

evaluate the centering of the process) are calculated.<br />

● design of experiments, which are experiments that involve<br />

changing one or more of the process inputs <strong>and</strong> measuring<br />

the results to one or more of the process outputs (15).<br />

Rapid microbiology test methods<br />

Another part of FDA’s PAT initiative involves discussion<br />

about the feasibility of developing so-called rapid microbiology<br />

methods (emphasis added, as most microbiological testing<br />

can take anywhere from several days to a couple of weeks<br />

to complete). This topic is of heightened interest within the<br />

industry as manufacturers seek additional ways to reduce cycle<br />

times.<br />

Rapid microbiology testing was discussed during the FDA<br />

Advisory Committee for Pharmaceutical Science meeting on<br />

23–24 October 2002 (16). During that meeting, the committee<br />

identified at least two problems or risks associated with the development<br />

of rapid microbiology methods; namely,<br />

● validation of test methods may not yield results equal to those<br />

for traditional test methods<br />

● acceptance by regulators (e.g., FDA).<br />

The group also categorized microbial determinations as follows:<br />

● qualitative methods (presence or absence of microbes; e.g.,<br />

sterility testing)<br />

● quantitative methods (enumeration of microorganisms present;<br />

e.g., microbial limits tests)<br />

● microbial identification.<br />

FDA did concede that rapid microbiology test methods are<br />

an important part of the PAT initiative but that at this time it<br />

has not yet been discussed extensively (16). FDA also commented<br />

that the general guidance document on PAT would not<br />

specify details about rapid microbiology methods but would<br />

rather cover them in a general sense to encourage their use. Finally,<br />

the group felt that microbial identification probably has<br />

the most rapid method systems presently available, <strong>and</strong> quantitative<br />

testing probably has the least detection systems.<br />

Real-time data information <strong>and</strong> management systems<br />

Another PAT tool being discussed is the use of real-time data<br />

information <strong>and</strong> management systems. Although a detailed<br />

overview of this topic is not provided in this article, some of<br />

the possible concerns include possible 21 CFR Part 11 implications,<br />

adding complexity to already complex computer system<br />

architecture, <strong>and</strong> the amount of data retention necessary, given<br />

that continuous monitoring will generate very large volumes<br />

of data.<br />

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With FDA’s recent withdrawal of Part 11 guidance documents,<br />

it would be advisable to first review the anticipated PAT guidance<br />

document for information concerning data information<br />

<strong>and</strong> management issues <strong>and</strong> secondly review the 21 CFR Part<br />

11 implementation portion of the “Pharmaceutical CGMPs for<br />

the 21st Century Initiative,” which includes both a Notice of<br />

Availability <strong>and</strong> a draft guidance on Part 11. The draft guidance<br />

on Part 11 attempts to clarify the scope <strong>and</strong> applicability of the<br />

regulation, which ultimately may undergo revision to clarify<br />

the scope <strong>and</strong> requirements.<br />

Benefits <strong>and</strong> challenges: an industry perspective<br />

Most industry representatives that either were involved in discussions<br />

regarding the feasibility of PAT or who have conducted<br />

successful PAT efforts thus far have had many more positive<br />

than negative comments regarding the advantages of adopting<br />

PAT principles. Positive perceived benefits of PAT include<br />

● decrease in cycle times<br />

● lower costs<br />

● increased efficiency <strong>and</strong> batch-to-batch consistency<br />

● process fingerprinting (signature) that would be useful for validation,<br />

scale-up, <strong>and</strong> confirming acceptable h<strong>and</strong>ling of changes<br />

● increased process underst<strong>and</strong>ing <strong>and</strong> a decrease in variability,<br />

rejects, <strong>and</strong> lot failures<br />

● possible continuous processing <strong>and</strong> the ability to adjust process<br />

on the basis of real-time monitoring data.<br />

Conversely, the most-common perceived or actual challenges<br />

include<br />

● product-approval delays by inclusion of PAT methodologies<br />

into relatively traditional drug development <strong>and</strong> validation<br />

activities<br />

● lack of a written PAT guidance document from FDA<br />

● an increase in the amount of data being generated, including<br />

not only what one should do with the extra data but also possible<br />

Part 11 implications<br />

● increased pressures to meet aggressive filing timelines, added<br />

costs to make changes, lack of senior management support,<br />

<strong>and</strong> resource constraints (Source: Reference 1 <strong>and</strong> 2003 AAPS<br />

Arden House Conference.<br />

Where we go from here<br />

Although no one can clearly predict how widely accepted PAT<br />

will become, it is clear that FDA does support innovation. The<br />

agency is appealing to the industry to take a more active role in<br />

underst<strong>and</strong>ing its manufacturing processes <strong>and</strong> is seeking quick<br />

<strong>and</strong> effective resolution of problems associated with good manufacturing<br />

practices that result in rejected batches, stability failures,<br />

field alerts, <strong>and</strong> product recalls.<br />

Currently there are many actions a company can take to<br />

prepare for what FDA is calling the “GMPs for the 21st Century.”<br />

By reading the contents provided on FDA’s Web site regarding<br />

PAT (http://www.fda.gov/cder/OPS/PAT.htm), which<br />

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includes committee meeting minutes <strong>and</strong> dozens of presentations,<br />

one will see that many large pharmaceutical firms already<br />

have made significant accomplishments through the<br />

successful implementation of PAT principles. In spite of the<br />

industry’s dwindling profit margins, fewer new products in<br />

the pipeline, <strong>and</strong> a more competitive marketplace, these companies<br />

already have recognized the positive aspects of implementing<br />

PAT. The following are some active steps that a company<br />

can take right now.<br />

Develop a plan for the future.<br />

● Wait for FDA’s much anticipated guidance document about<br />

PAT before making significant decisions regarding how your<br />

company will h<strong>and</strong>le certain PAT principles (e.g., validation<br />

of new analytical methods for a unique in-process test).<br />

● Analyze existing product lines <strong>and</strong> determine which may benefit<br />

most from PAT. For example, the compounding <strong>and</strong> filling<br />

of a well-established product that is a true solution composed<br />

of 99.5% water is probably not the best c<strong>and</strong>idate for<br />

PAT. The manufacture of complex dosage forms such as<br />

tableted products, which also includes in-process monitoring<br />

using process control charts, would probably be a better<br />

choice. Products with recurring quality problems are also<br />

good c<strong>and</strong>idates because process deviations or exceptions are<br />

sometimes results of a less-than-complete underst<strong>and</strong>ing of<br />

the process rather than more-obvious causative factors.<br />

● Obtain/retain employees with education, training, <strong>and</strong> experience<br />

in disciplines necessary to be successful in PAT efforts.<br />

For example, FDA is seeking to hire persons experienced in<br />

in-process/chemical engineering, PAC, chemometrics, <strong>and</strong><br />

industrial pharmacy. For your company’s efforts to be successful,<br />

similar expertise will be needed.<br />

● Gain executive management’s support for PAT. Although it<br />

may be easier to make the scientific case, management must<br />

underst<strong>and</strong> how PAT could reduce cycle times <strong>and</strong> costs <strong>and</strong><br />

add value. Make a business case for adopting PAT.<br />

Benchmark with industry <strong>and</strong> academic partners. Speak with<br />

company representatives from firms that already are using PAT<br />

principles. Many major universities also are heavily involved in<br />

the PAT initiative <strong>and</strong> could provide guidance, including, but<br />

not limited to, the following schools that have had representatives<br />

at several FDA committee meetings about PAT:<br />

● MIT Pharmaceutical Manufacturing Initiative<br />

● Purdue University, School of Pharmacy<br />

● Center for <strong>Process</strong> <strong>Analytical</strong> Chemistry at the University of<br />

Washington.<br />

● Texas A&M Department of Chemistry <strong>and</strong> Chemical Engineering.<br />

Gather information about the topic. A significant amount of information<br />

concerning PAT can be found on FDA’s Web site (1).<br />

Additional new information continues to be added, <strong>and</strong> plenty<br />

of information already is available on many university <strong>and</strong> industry<br />

association Web sites regarding topics such as PAT, PAC,<br />

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PCA, <strong>and</strong> chemometrics. Internet keyword searches can yield<br />

significant additional information.<br />

Attend future PAT workshops, seminars, or symposia. Find out<br />

what FDA <strong>and</strong> others are saying first-h<strong>and</strong>. If the workshops<br />

are sponsored by an industry association, you may need to attend<br />

in person to get the h<strong>and</strong>outs <strong>and</strong> presentations because<br />

all of that information may not be published on FDA’s or the<br />

association’s Web site.<br />

Provide comments directly to FDA using the Internet. If you have<br />

substantial comments regarding FDA’s PAT initiative <strong>and</strong> you<br />

feel it is information that others could benefit from, consider<br />

providing electronic comments to FDA. The agency already has<br />

established a Web-based feedback tool for this purpose (www.<br />

fda.gov/ohrms/dockets/). You will need to search for docket<br />

number 03N-0059. Alternatively, you could send questions or<br />

comments regarding the PAT initiative by email to<br />

pat@cder.fda.gov.<br />

Ensure quality is designed into your products <strong>and</strong> processes.<br />

● Confirm compliance with good manufacturing practices. Remember,<br />

CGMP is the minimum st<strong>and</strong>ard according to 21<br />

CFR 211.1(a). Most of the successful companies strive for <strong>and</strong><br />

achieve substantial compliance with these regulations as well<br />

as carry out “best practices.” Poorly developed manufacturing<br />

processes, untrained employees, or equipment that has<br />

not been properly qualified will hinder any PAT efforts.<br />

● Complete thorough product <strong>and</strong> process development work<br />

to ensure processes are adequately defined. Include robust<br />

specifications <strong>and</strong> critical process-control points.<br />

● Confirm that active drug substances are well characterized.<br />

● Use validation efforts to demonstrate consistency <strong>and</strong> reproducibility,<br />

not as a means to conduct range finding, process<br />

adjustments, or enhancements. These are development tasks,<br />

not validation.<br />

● Optimize processes <strong>and</strong> improve yields after successful validation,<br />

not during validation.<br />

● Consider process or equipment changes carefully, especially<br />

postapproval, because this usually will result in much unanticipated<br />

work <strong>and</strong> undoubtedly more development activities<br />

<strong>and</strong> data. Complete risk or impact assessments on the<br />

basis of data <strong>and</strong> not on opinions or theories.<br />

Many years ago, Alex<strong>and</strong>er Hamilton said,<br />

Experience teaches that men are often so much governed<br />

by what they are accustomed to see <strong>and</strong> practice, that the<br />

simplest <strong>and</strong> most obvious improvements, in the most<br />

ordinary occupations, are adopted with hesitation, reluctance,<br />

<strong>and</strong> by slow gradations. Men would resist<br />

changes, so long as even bare support could be ensured<br />

by an adherence to ancient courses, <strong>and</strong> perhaps even<br />

longer.<br />

Sometimes changes do take time, so we should look to the<br />

future potential of PAT to enhance our pharmaceutical processes<br />

Continued on page 254<br />

Circle/eINFO 51<br />

66 Pharmaceutical <strong>Technology</strong> OCTOBER 2003 www.pharmtech.com


Continued from page 66<br />

<strong>and</strong> applaud FDA for encouraging the application of new technologies<br />

<strong>and</strong> for their willingness to work with industry on this<br />

important initiative.<br />

Acknowledgment<br />

The author would like to acknowledge the following individuals<br />

for their assistance in the writing of this article: KMI senior<br />

compliance consultant Eric S. Weilage <strong>and</strong> PAREXEL senior<br />

biostatistician Chunzhang Wu, PhD.<br />

References<br />

1. CDER, Office of Pharmaceutical Sciences, “<strong>Process</strong> <strong>and</strong> <strong>Analytical</strong><br />

Technologies Initiative,” http://www.fda.gov/cder/OPS/ PAT.htm.<br />

2. A. Hussain <strong>and</strong> J. Famulare, “FDA’s PAT Initiative <strong>and</strong> its Role in the<br />

Proposed Drug Quality System for the 21st Century,” presented at the<br />

AAPS Arden House Conference, 27 January 2003.<br />

3. T. Layloff, “<strong>Process</strong> <strong>Analytical</strong> <strong>Technology</strong> (PAT) Subcommittee Report,”<br />

presented at the ACPS meeting 21 October 2002.<br />

4. FDA,“Pharmaceutical CGMPs for the 21st Century: A Risk-Based Approach,”<br />

http://www.fda.gov/cder/gmp/index.htm.<br />

5. P. Hailey et al.,“Automated System for the On-line Monitoring of Powder<br />

Blending <strong>Process</strong>es Using Near-Infrared Spectroscopy Part I. System<br />

Development <strong>and</strong> Control,” J. Pharma. Biomed. Analysis 14,<br />

551–559 (1996).<br />

6. D. Illman,“CPAC: An Industry–University Cooperative Research Center<br />

for <strong>Process</strong> <strong>Analytical</strong> Chemistry,” TrAC: Trends in <strong>Analytical</strong> Chemistry<br />

5 (7), 164–172 (1986).<br />

7. S. Wold,“Chemometrics: What Do We Mean with It <strong>and</strong> What Do We<br />

Want from It?” presented at InCINC ’94, Institute of Chemistry, Umea<br />

University (Umea, Sweden, 1994).<br />

8. B. Wise <strong>and</strong> N. Gallager, “The <strong>Process</strong> Chemometrics Approach to<br />

<strong>Process</strong> Monitoring <strong>and</strong> Fault Inspection,” J. Proc. Ctrl. 6 (6), 329–348<br />

(1996).<br />

9. J. Hardy, “Special Topics: Chemometrics,” lecture presentation associated<br />

with 3150: 710 (University of Akron, 2000), available at<br />

http://ull.chemistry.uakron.edu/chemometrics/introduction.<br />

10. FDA,“Emerging Issues in Pharmaceutical Manufacturing: <strong>Process</strong> <strong>Analytical</strong><br />

<strong>Technology</strong>,” science board meeting presentation (16 November<br />

2001).<br />

11. N. Sugakkai,“Iwanami Sugaku Ziten,” original publication by Iwanami<br />

Shoten Publishers (Tokyo, Japan, 1954), copyright by Nihon Sugakkai<br />

(Mathematics Society of Japan); English translation provided by the<br />

Massachusetts Institute of <strong>Technology</strong> (1977).<br />

12. D. Sans, R. Nomen, <strong>and</strong> J. Sempere, “Interactive Self-Modelling of<br />

Chemical Reaction System Using Multivariate Data Analysis,” supplement<br />

to Comput. Chem. Eng. 21, S631–S636 (1997).<br />

13. W. Wu et al.,“The Star-Plot: an Alternative Display Method for Multivariate<br />

Data in the Analysis of Food <strong>and</strong> Drugs,” J. Pharma. Biomed.<br />

Analysis 17 (6-7), 1001–1013 (September 1998).<br />

14. P. Nomikos <strong>and</strong> J. MacGregor,“Multiway Partial Least Squares in Monitoring<br />

Batch <strong>Process</strong>es,” Chemometrics <strong>and</strong> Intelligent Laboratory Systems<br />

30, 97–108 (1995).<br />

15. FDA Global Harmonization Task Force Study Group #3, draft <strong>Process</strong><br />

Validation Guidance (1 June 1998).<br />

16. FDA Advisory Committee for Pharmaceutical Science transcripts, 23<br />

October 2002. PT<br />

Jump to<br />

254

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