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Working with your process to develop a specialized solution.
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You know you have crossed some irreversible line in the parent/ British Columbia, Canada michael.kelly@advantagemedia.com
KEITH JORDAN
child relationship when your 68 year old mother asks you if you AL, CT, DC, FL, GA, 25 Northwest Point
know anyone who can get her marijuana. IA, IL, IN, MA, MD, Elk Grove Village, IL 60007
ME, MS, NC, NH, RI, Tel: 973-920-7755
This request didn’t come from some Woodstock-era hippie look- SC, TN, VA, VT, WV, WI, Fax: 973-607-5675
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After I picked myself and the phone receiv- Fax: 973-607-5460
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Reprints NICHOLAS J. IADEMARCO
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I think it’s time for this country to stop making the moms, dads hereby disclaims any liability to any person for any loss or dam-
age caused by errors or omissions in the material contained herein,
and grandparents of this country into "criminals". regardless of whether such errors result from negligence, accident
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My E-mail is: mike.auerbach@advantagemedia.com
Tumble Mixer Achieves Real Time IBC Tablet Inspection Machine Provides
Blend Uniformity Pressure Gauge Takes Measurements Rapid And Reliable Analysis
Company offers a “plug and play” Near-Infrared In Harsh Media Applications The PharmaLIBS™ 250 tablet inspection
PAT System for blend uniformity analysis for IBC The Type 5503 differential pressure gauge pro- machine is a laser-based analytical instru-
tumble blending. The LANCIR II System’s design vides reliable low differential pressure measure- ment designed for testing solid and oral
consists of a self-contained, battery operated ment in high static, wet-wet pressure applica- dosage pharmaceuticals. It is a mobile and
wireless NIR diode array spectrometer mounted tions. Equipped with wetted materials of 316SS, user-friendly tool for quick decision-mak-
on an IBC. The wireless signal can be received Monel or Hastelloy C, the rugged Type 5503 D/P ing. Analyses are performed directly on the
up to 1,000 feet away from a wireless PC running pressure gauge is specifically designed to moni- tablets without any sample preparation or
the system’s proprietary software. tor a wide variety of caustic liquids and gases. requiring solvents.
Custom Powder Systems, Springfield, MO Ashcroft Inc., Stratford, CT 06614. www. Eisai Machinery U.S.A. Inc., Allendale, NJ
65803. www.custom-powder.com or call 417- ashcroft.com or call 800-328-8258 07401. www.eisaiusa.com or call 201-746-2111
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• Customized solutions.
• Isolated processing areas on all machines
due to special sealing systems.
• Isolation at product loading and exit
due to isolators and high containment valves.
all O.E.B. categories. • Possibility to install in-line indirect methods
to control the high containment
manufacturing process.
• Special solutions for the treatment of air
exhausted from the processing area and
dust extracted from the machines during
production.
• Clean In Place systems.
H A N D L I N G • G R A N U L AT I O N • TA B L E T I N G • C A P S U L E F I L L I N G A N D BA N D I N G • W E I G H T C H E C K I N G • COAT I N G • WA S H I N G
Delivering Excellence
Innovative equipment applications and a forward-looking design help build an
advanced API facility
■ By Mike Auerbach, Editor-In-Chief
O
rchid Chemicals & Pharmaceuticals Limited’s AUTOMATION A KEY FACILITY DRIVER
desire to build a cost effective, well-integrated, At Orchid, automation was implemented for various reasons
intermediate and sterile API facility, with state- and was a major part of the facility design. All equipment is au-
of–the-art building/technical concepts and tomated by using tools like Distributed Control System (DCS)
equipment has resulted in their Aurangabad carbapenem or Programmable Logical Controllers (PLCs). DCS or PLCs are
facility winning the 2009 Facility of the year award for technological tools commonly available in the market but their
Regional Excellence. application in API manufacturing is unique.
Commenting on the reason why automation was used so
ABOUT THE COMPANY extensively in the plant, Mr. V .S. Padalkar – Vice President
Orchid Chemicals & Pharmaceuticals Limited is an inte- of Projects & Engineering at Orchid said, “(The) primary
grated pharmaceutical company based in Chennai (Madras), aim in designing the facility (with a high level of automa-
India. Located approximately 400 kms away from Mumbai; tion) was human and product safety, consistency in all oper-
the Aurangabad facility is intended for the manufacturing of ations, and technological excellence to motivate and attract
non-penicillin - non-cephalosporin APIs, penicillin APIs, and talented employees.”
carbapenem APIs.
The carbapenem based product manufacturing sec- ADVANCED FACILITY DESIGN – AVOIDING
tion of the factory has four (Intermediate/API/Sterile/ CONTAMINATION
Hydrogenation) production blocks supported by a dedicated As the Aurangabad location is designed for multiple prod-
solvent recovery plant, water systems, various utilities, an ucts, it was a great challenge to incorporate various types
effluent treatment plant and warehouse. These facilities of product manufacturing blocks with a special emphasis on
were newly constructed in fiscal year 2006-2007 and are avoiding cross contamination, environment awareness and
well integrated in terms of layout planning, cGMP building advanced safety features.
design, state-of-the art systems, and innovative equipment. The new facility comprises eight distinct blocks:
Special emphasis has been given to the design of the pro- 1.) Intermediate block (Plant-17)
duction facilities so contamination and cross contamination 2.) API block (Plant-31)
can be avoided. 3.) Hydrogenation block (Plant-41)
Left: Partial view of the Auraganbad facility from the main entrance. Above: Corridor around the cleanroom with the
adjacent technical area. Right: The advanced powder handling system featuring split valves.
INTERPHEX.
NOW AVAILABLE IN TORONTO.
its vent was open to atmosphere so there was no assurance the inerti- '“Their timeline and safety record were very good, especially con-
zation of the centrifuge was effective and there was a huge consump- sidering the location. This project was well-executed and the first to
tion of nitrogen as well. To eliminate this unsafe procedure, Orchid use certain technologies in India. They brought in a lot of technology
developed an innovative blanketing system with their supplier. in a place where it’s difficult to do so. The challenges and how they
Nitrogen purging and blanketing of the centrifuges consists of a overcame them are appreciated.
series of pressure reducing valves to get to the required pressure They were able to increase their productivity all with local expertise”'
and has back pressure regulated valves at the vent to hold the We have built a facility for the present and future with advanced
specified nitrogen inside the centrifuge basket for inertization pur- technologies with in-house expertise only. This project is a unique
pose. Pressure switches are provided to monitor the nitrogen pres- blueprint in many ways for our kind of industry - a multi-product
sures which are interlinked to the control system. This blanketing flexible facility, with reduced product cost, increased productivity,
system provided following advantages: fully in-house expertise, an excellent safety record, strict compliance
• Ensure proper inert atmosphere in the centrifuge for safety. to cGMP, and superb team efforts with extraordinary leadership."
• Avoid loss of nitrogen thereby reducing nitrogen consumption.
Orchid has realized a 90% reduction in the use of nitrogen; saving a
lot of energy.
• Since the system is closed solvent lost to the atmosphere is BioSafe™ Pass-Throughs
eliminated and pollution significantly reduced.
• Ensures consistent product quality, less human exposure and
operator interference.
When asked about the relationship between the company and its
suppliers, and the requirement for the development of many new,
proprietary processes/equipment, Mr. Padalkar explains, "Orchid
strives to bring excellence in any work we do, whether it is pro-
cesses, hardware, facility, environmental protection, safety, cGMP
and so on.
This is not just to meet any statutory or regulatory requirements
for the time being, but to surpass such requirements and be at the
forefront of technical superiority in our industry.
Some of the concepts, even though they were new to vendors,
were so well co-ordinated with the vendors that the provided state-
• Seamless — Unique design eliminates cracks, corners
of-art solutions benefitted both our company and the vendors. and other contaminant traps!
Most of them were quite receptive of any changes and trying out • Lipless — Easy material transfer with no clearance
obstruction
new ideas for the first time. It was really a great learning and trail-
• Easy to Clean — Ultra-smooth internal surfaces
breaking experience for both sides." • Easy to Sterilize — 304/316 SS; removable doors can
Non-contaminating be autoclaved
polyurethane BioSeal • Double-Wall, Sealed Construction — adds rigidity
SUMMING IT ALL UP with no-lip design
and houses interlock and utilities
Finally, when asked why he thought the Facility of the Year judges
selected his facility for the award, Mr. Padalkar offer this explanation,
To order : 714-578-6000
"We are very proud and overwhelmed by this prestigious recogni- Fax: 714-578-6020
tion. The following comment by the respected judges reflects our
Low-Cost Solutions for High-Tech Industries
uniqueness and special efforts taken in this project to meet timelines
and budget with utmost safety and cGMP at every step of project.
GlaxoSmithKline Cuts
Drug Development Time by
Using Jacketed Lab Reactors
Mini versions of production equipment provide a wealth of scale-up information
T
he traditional way to develop a process for pro-
ducing a new drug is to do the initial develop-
ment in round-bottomed laboratory flasks and
make the transition to small-scale production-
type reactors when the process is ready for piloting. Many
pharmaceutical companies still do it this way, but more
and more companies are switching from flasks to labora-
tory-scale jacketed reactors that are miniature versions of
production equipment.
The chief advantage to using a jacketed lab reactor is that re-
searchers can obtain information early in the process-develop-
ment stage on how a process will work in actual production, in-
cluding data on the safety of a process, says Roy Flanagan, team
manager of process safety and design with GlaxoSmithKline’s
Chemical Development
Dept. in Research Triangle
Park, NC. This enables a
company to get a drug to
market faster and more
than justifies the cost of the
equipment, he says.
GlaxoSmithKline plc
(GSK), for example, has
invested hundreds of
thousands of dollars on
jacketed lab reactors for
its Worldwide Research &
Development operations,
says Flanagan, but has
likely saved millions of
dollars by getting critical
information early in the
development of a process.
“A blockbuster drug can
generate revenues of $1
billion/yr, or $3 million/
day,” he points out, “so
getting products to the
Above: A scientist drains product from the manual bottom valve of a 2-L jacketed market faster can have a
lab reactor. large positive effect on
Right: A 2-L reactor with associated vapor trap (right) and distillate receiver (the the bottom line.”
glass ball). An insitu IR probe is inserted into the vessel on the left via a glass In contrast, he says, the
adapter (blue cap).
Left: Another view of the 2-L jacketed lab reactor. In the foreground is a programmable direct-
displacement pump for metered, mass dosing.
Above: A 2-L jacketed lab reactor with a dosing bottle on a scale at left.
fact that a process has worked well through scale-up from RTP is a relatively small department, with about 150 em-
small to large flasks is no indication that it will work well in ployees, but it has developed processes for some high-pro-
production. “In the past, when we used flasks, we had some file drugs, such as the AZT AIDS drug, Valtrex for herpes,
unpleasant surprises the first time we tested a process in Zyban for smoking cessation, and the Avodart prostate
a pilot reactor, and many times we had to go back and re- treatment. At any one time the department may be working
develop a process. We have had far less of these problems on 15–20 projects, says Flanagan.
since we adopted the jacketed lab reactors. We typically
identify problems early and solve them before we get to the SCALED-DOWN PILOT PLANTS
pilot stage.” Chemical Development has 29 jacketed lab reactors,
Another basic advantage of using a jacketed lab reactor all supplied by De Dietrich Process Systems, Inc. (De
is safety. Flanagan points out that product is removed from Dietrich calls them Miniplant reactors). GSK also uses De
a lab reactor through a valve at the bottom of the vessel, Dietrich pilot-scale reactors in its pilot plant operations
whereas a flask is usually emptied by picking it up. “It can in Philadelphia. Using equipment from the same manu-
be dangerous having people picking up a 22-L flask,” he facturer at both the development and pilot stages makes
says. “Also, if you heat up a flask using a traditional mantle for a smooth transition in the scale-up of a process, says
and the reaction starts to run out of control, there’s no way Flanagan. “Our lab reactors are scaled-down versions of our
to cool it.” pilot plant vessels,” he says, “just as our pilot plants are
While GSK has used jacketed lab reactors at some sites scaled-down versions of production equipment.”
for several years, during 2005 and 2006 Flanagan led a The 29 jacketed lab reactors at RTP consist of five 1-L
multi-site group to formalize the implementation of the tech- kits, six 2-L kits, two 6-L kits, six paired 20-L kits (12 ves-
nology in all of the company’s five major research centers. sels), and two paired 50-L kits (four vessels). All of the
GSK continues to improve the use of the technology through smaller kits are made of durable borosilicate glass and
a laboratory reactor “site champions group” that has a rep- most are elliptical in shape, rather than round-bottomed, so
resentative from each of the five centers. their mixing characteristics are similar to those of a typical
The Research Triangle Park (RTP) operation is one of production-size reactor. A couple of conical-shaped vessels
two U.S. headquarters sites for GSK, the other being in have also been installed for specialized studies. The 50-L
Philadelphia, where the company has one of its pilot plants. kits are made of glass-lined steel and Hastelloy, identical to
RTP has about 7,000 employees, of whom some 3,000 work those found in pilot plants.
in Research and Development. Chemical Development at The head of each lab reactor has a large central port for
the agitator motor, which has either a single up to the 6-L and 20-L reac-
or double mechanical seal to ensure that tors we are probably down to
the vessel contents are not compromised 30% development, and when
during operation. Several other ports are we get to the 50-L scale 90%
available for other purposes, including: the of the work is for produc-
addition of reactants and other materials tion of material for testing
(two ports), a glass riser for distillation and we are just tweaking the
overhead, a thermowell for temperature process.”
measurements, and other process analytical He explains that prepa-
technology (PAT) functions, such as turbid- ration of material at the
ity, near-infrared and pH measurements. smaller scale is mostly for
“The head has as many available ports as development studies, includ-
we can get away with,” says Flanagan. ing toxicity tests, but at the
In the glassware above the reactor is 50-L scale an active ingredi-
a manual valve that allows either reflux ent is made in quantities of
or removal of distillate. Each of the small up to 5 kilos and supplied
reactors has a graduated receiver for distil- to RTP’s Pharmaceutical
late, but each pair of 20-L and 50-L vessels Development Department,
shares a single condenser and valves which which determines the best
allow distillate to flow from one vessel to way to formulate a product
the other. “This gives us the flexibility to re- for use by patients (e.g., as a
flux or distill from either vessel throughout tablet, capsule, or by inhala-
the entire process,” says Flanagan. “There is tion). Some of the product
also a phase separator between them, so we may also be used in early-
can perform an azeotropic removal of water phase clinical trials.
and direct either phase to either vessel.” The use of jacketed lab
Product is removed through a valve at reactors has also enabled
the bottom of the vessel — a manual valve GSK to develop GMP (Good
on the smaller reactors and a pneumatically Manufacturing Practice)
operated valve on the 20- and 50-L units. clean-in-place and clean- Close-up of a 20-L jacketed lab reactor with a glass-
The design of the valve practically eliminates ing verification procedures as a process lined, retreat-curve (similar to production vessels) and
a pneumatically operated bottom valve.
dead space and makes for a free flow of is scaled up. In addition, the company has
product through the valve, says Flanagan, performed equipment qualification exer- stration of the process on a small scale.”
so that essentially all of the product can be cises on all the lab reactors that are used Other cases have involved heterogeneous
evacuated. In contrast, a round-bottomed for clinical material preparations. reactions that use heavy, solid catalysts such
flask is normally picked up to be emptied as zinc-based or base metal catalysts that tend
and this can be a rather hazardous pro- IDENTIFYING to settle to the bottom of the vessel. These
cedure for larger vessels, as noted earlier. PROBLEMS EARLY processes “may work beautifully in a round-
Alternatively, product may be vacuumed Flanagan cites a number of examples bottomed flask” because the stir bar or paddle
from a flask — a problematic operation. where the jacketed lab reactors have re- is in contact with the bottom of the flask and
Work on new drugs starts in RTP’s Drug vealed problems in the early stages of pro- grinds up the metal, says Flanagan. In contrast,
Discovery Department, where potential drug cess development. “There have been cases the agitator in a reactor is not in contact with
candidates are made in quantities of up to where we have identified balling issues in the bottom of the reactor, so the mixing is not
a few grams in standard glassware. Those our small reactors that we may not have as efficient. “Now, when we identify that kind
that show promise are moved on to Chemical seen in round-bottomed flasks.” The reason, of problem in a lab reactor, we work with our
Development, where processes to make ac- he says, is that mixing is done in a flask by engineers to ensure that the appropriate geom-
tive ingredients are initially scaled to produce a stir bar or paddle, whose mixing action is etry is selected for the scale-up of the agitator
quantities of up to 100 grams in 1- or 2-L jack- different from that of an agitator in a reac- or of the reactor,” he says.
eted lab reactors. It is at this scale that most tor. In vacuum distillation processes, scaling
of the process development is done and basic “The effect of agitation with a miniature on the reactor wall is a problem that may
problems are solved, says Flanagan. agitator is similar to that of a full-scale present itself when a process is upgraded
“In these smaller reactors we devote al- plant agitator in terms of power per unit from a flask to a pilot plant reactor. As the
most 100% of the work to process develop- and shear effects,” he says. “You can also batch is concentrated, scaling occurs on the
ment and very little to making material to model your process to use real heating and vessel wall above the level of the process
support studies,” he says. “When we scale cooling times to get a more realistic demon- liquid. This happens because the heated
WHAT’SHOT
stallation time. Starweigh™ delivers laboratory
accuracies in production environments allow-
ing users to maintain tight tolerances through-
out the packaging process. The system can
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ranging from 30 cc to 2000 cc; even difficult to
handle oval and rectangular containers in plas-
tic, glass, or metal can be inspected. Sustained
Gravimetric Additive Feeder accuracies from +/- 2 mg are delivered at rates
Provides Accurate Metering up to 400 cpm, ensuring high quality products
And Precise Control which meet demanding production targets.
The CF-1000 Series gravimetric additive feeder, The system also offers configurable user
features a compact feeder that provides ac- security, on-screen “help” functionality, and
curate metering of additives as well as mate- multilingual operation for maximum workforce
rial usage tracking, which can be utilized in flexibility. Advanced communications interfac-
all molding and extrusion applications for es enable transfer of valuable data to informa-
pelletized materials. The CF-1000 adds colorant tion networks and real time machine status
or other free-flowing material to your process, to SCADA and other factory floor automation
RFIDTag Withstands based on a self-calibrating gravimetric control- systems for fast, error free process integration.
ler. This eliminates the over-feeding that typi- ■ Mettler-Toledo Hi-Speed, Ithaca, NY 14850.
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cally accompanies volumetric feeders. There
Cumulative Exposure to is automatic calibration if there is a deviation
Gamma Radiation from the set additive weight; and flow rate is
The GammaTag 500, is ideal for high volume calculated in both percentage or kilograms
items requiring repeated gamma sterilization per hour for extruders. Standard features
and is well suited for the pharmaceutical indus- include: a user-friendly graphic display,
try. The tag was developed for single use pro- integrated TCP/IP card that enables com-
cess components and other critical parts for munication for injection molding models,
pharmaceutical applications. It is a read/write a 0-10 VDC extruder follower circuit
tag used to identify, record, and access the available on extrusion models, and an ad-
current status of process components on the vanced feed-rate algorithm. An integrat-
spot. Information such as manufacture date, ed automatic venturi loader,
part number, lot number, gamma sterilization along with other side-
date, and other important data may be written loading configurations, is
to and retrieved from the tag’s memory. It optional. ■ Colortronic
handles typical doses of 25 kGy and a cumula- North America, Inc.,
tive amount of at least 500 kGy with no loss of Flint, MI 48507. www.
data. ■ AdvantaPure, Southampton, PA 18966. colortronicna.com or
www.advantapure.com or call 888-755-4370 call 810-720-7300
Modular Cleanrooms
and Laboratories
To order : 714-578-6000
Fax: 714-578-6020
Compliance Documents:
Solving the Puzzle
Pharmaceutical ERP software for stress-free regulatory compliance
■ By Jay Deaking, President, Deacom, Inc.
P
harmaceutical manufacturers operate in one of PUZZLE PIECES
the most highly regulated industries – facing The typical process of business growth is how most
an array of restrictions and requirements from pharmaceutical manufacturers end up with the patchwork
the FDA, EPA, OSHA, various state and foreign of software systems that complicates reporting. A company
governments, and their individual customers. Integral to may start out managing many processes, such as formula-
meeting these groups’ standards are the various compliance tion and quality control (QC), with notebooks and spread-
documents they require, such as product labels, Material sheets, and others, such as accounting, with standalone
Safety Data Sheets (MSDSs), SARA reports, Certificates of software systems. At this stage, any data that must be re-
Analysis (COAs), and shipping papers. ported to the FDA, EPA, or other organizations can be read-
For many drug makers, producing these documents in ily found among the relatively small amount of data.
an accurate and timely manner is a significant challenge, However, as business volume grows, more formulas are
if not an outright headache, because of the use of multiple developed and tested, products are pushed into production,
software systems to run their businesses. When using dis- and new customers begin knocking at the door. At that time,
connected systems, spreadsheets, and/or word processing manufacturers struggle to fit the data puzzle pieces together
programs to manage data, manufacturers can spend hours to create the reports they need. Perhaps a formula manage-
or days gathering information, making calculations, and en- ment software system, or a system to handle inventory man-
tering the results into word processing documents. agement was added. Now, with more data being created and
But with today’s technology, this labor-intensive and po- stored in more places, generating the required regulatory
tentially error-ridden process is unnecessary. As this article reports can become time consuming and tricky.
will discuss, pharmaceutical manufacturers using a single, Often, companies using multiple, disparate systems ask one
fully-integrated pharmaceutical ERP software system can person to handle all reporting. This person, perhaps a techni-
integrate regulatory reporting with all other business pro- cal or compliance director, keeps track of which forms are due
cesses to solve the compliance document puzzle and make at what times, to what organizations, and what information
regulatory reporting a stress-free operation. they require. He searches each system for the appropriate
Well-designed
ERP software
should integrate
all the data of a
pharmaceutical
manufacturer,
including formu-
lation, regula-
tory reporting, REGULATORY ORDER PURCHASING
LABORATORY REPORTING ENTRY
purchasing, pro-
duction, inven-
tory, sales, and
accounting in
one system.
data, makes any calculations, enters the information tabase, there is no need to link to other programs or search
into the right form, and prints the documents. He disconnected or paper-systems for document generation.
does this for COAs, product labels, MSDSs, an- When a document is regulated in the system, it’s filled in
nual SARA reports, and more. with the most up-to-date data automatically.
Unfortunately, no matter how diligent For example, because the system stores all formulation, pro-
this person is, whenever reporting is not duction history, purchasing, and sales data, it can automatically
integrated with business data, the process is calculate the hazardous material amounts required for SARA
open to inefficiencies and errors. For one, manu- reports and show the figures in the appropriate template fields.
facturers create a bottleneck by funneling all reporting to
one person. Deadline-sensitive documents may stack up LOW-STRESS REPORTING
when, for example, this person goes about researching and With document generation integrated within a compre-
completing Form Rs – the lengthy SARA reports required hensive pharmaceutical ERP software system, drug makers
for each toxic chemical manufactured, processed, or used avoid the problems associated with using a patchwork of
beyond certain EPA thresholds. Time spent waiting for docu- systems. The puzzle-piece approach to reporting is replaced
ments in the queue is time wasted, perhaps time that ship- by a streamlined and compliant reporting process that can
ments can’t go out the door, and this unnecessarily adds to provide greater productivity and a competitive edge.
the cost of doing business. Efficiency is one advantage gained by managing regula-
Errors are likely, as well. The director may choose the tory reports this way. Rather than having your compliance
wrong form, or simply make data entry errors or accidental director search each system for data to calculate and plug in
omissions. When mistakes are passed along to custom- to each word processing-based report, the system pulls and
ers, companies may face the costs and customer back- populates the data automatically. This saves countless hours
lash associated with returned shipments – such as extra over the course of a year, allowing companies to direct their
freight charges, refunds, and potentially a loss of business. compliance efforts to other processes. In fact, any system
Mistakes reported to the FDA, EPA, or OSHA could results in user with the proper security clearances can generate a COA
fines and regulatory scrutiny. or other document once the template has been configured.
Overall, a multiple-system environment can complicate Errors are reduced with this type of system, as well, be-
reporting and put a pharmaceutical manufacturer at a com- cause manual data entry is eliminated. Process controls in
petitive disadvantage. a fully-integrated system can also help manufacturers guard
against errors that, if unnoticed, could end up on a regulatory
PUTTING IT ALL TOGETHER document. For example, the QC process in a well-designed
Pharmaceutical manufacturers can create a more efficient ERP system should allow manufacturers to set pre-defined test
and accurate reporting process by integrating all their busi- ranges for each product. Then, if a user enters a value that
ness processes – formulation, QC/QA, production, inventory falls outside that range, the system would provide a screen
control and lot tracking, sales, purchasing, accounting, and prompt highlighting the error. Not only does this guard against
regulatory reporting – in one software system designed for typos that could end up on important documentation, it also
the pharmaceutical industry. helps you more easily identify products that do, in fact, fall
When all data is stored in a single, pharmaceutical ERP outside QC ranges and need to be altered or discarded.
system, report generation is no longer like trying to assem-
ble a complex puzzle. Because all the pieces required for CONCLUSION
each document – raw material usage and properties, QC test With all the regulations facing manufacturers in the
results, sales order information, formula data, and the like competitive pharmaceutical industry, companies shouldn’t
– are all managed in real time within the ERP system, report spend hours preparing their compliance documentation.
generation can become an automatic process. Utilizing a single, integrated ERP software system designed
In a well-designed system, companies would set up config- for pharmaceutical manufacturing can streamline the regu-
urable document templates for each report they are required latory reporting process through configurable document
to produce. A configurable form is one a manufacturer can templates for a faster, error-free process. With the regula-
adapt within the ERP system to fit its business needs, without tory compliance document puzzle solved, drug makers can
needing to alter the software’s programming code. A familiar focus on what really matters – their business.
program such as Microsoft Word will let users configure the
documents by arranging data fields, logos, and other charac- About the author:
ters to create the design, and include the data of their choice. Jay Deakins is the President of Deacom, Inc., the producer of
Once configured, the ERP system can automatically popu- an integrated accounting and ERP software system for mid-
late these forms with the proper data. Each data field on to-large-sized pharmaceutical and chemical manufacturers
a form will map to a particular data point in the database. with hard-to-handle requirements. Contact Jay at info@dea-
Because data from all processes is stored in that single da- com.net or visit www.deacom.net.
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12 Key Steps to
Address USP Changes
Strategies to stay current with the recent changes to Chapters <61> and <62>
R
ecently, the United States Pharmacopeia (USP) changes. Also, media for enrichment, subculture and selec-
General Microbiology chapters have harmonized tion have changed for most microorganisms.
with corresponding microbiology chapters in the
3
European and Japanese Pharmacopeias (EP and Find out how the changes apply to inventory that was
JP). The goal of pharmacopeial harmonization is to promote validated with current (prior to May 2009) standards.
consistency of microbiology methods used by companies glob- Based on changes in these harmonized chapters, prod-
ally. This harmonization includes revisions to the existing USP ucts may need to be revalidated. Reasons include, but are not
<61> Microbial Limits Test that creates two new chapters: USP limited to, media requirements, testing conditions and the
<61> Microbial Enumeration and USP <62> Absence of Specified amount of sample to be used. For example, if you are using
Organisms. Celsis International plc – a provider of life sci- the USP method and want to continue to use it but the media
ence products and laboratory services to the pharmaceutical, has changed, you will need to revalidate using the new media.
biopharmaceutical, and consumer products industries – out- Companies should also consider the possibility of a sample
Understand how the new chapters impact the requirements for growth and
recovery of specified microorganisms and specified microorganisms tests.
lines the key steps the pharmaceutical industry should take to that previously used a specified dilution not being acceptable
ensure they are ready to address these harmonization changes. at that same dilution with the newly specified media.
4
KEY STEPS TO PREPARE FOR Know how changes to USP <61> will alter sample
HARMONIZATION CHANGES amounts for bulk vs. small batches. Depending on
Following are the top steps companies in the pharmaceu- the test or combination of tests, the required sample
tical industry should take to ensure they are prepared for amounts may vary. As per harmonized USP <61> in the sec-
changes to the General Microbiology chapters USP <61>: tion covering testing of products, the amount used for the
Microbial Limits Testing and the addition of USP <62>: test should be 10g or 10mL. For fluids or solids in aerosol
Absence of Specified Organisms. form, it is necessary to test 10 containers. For transdermal
patches, 10 patches are to be tested. Additional information
1
Understand that changes to the USP will not affect to justify using less product is provided in the harmonized
alternate microbial test methods, such as Rapid chapters; examples include small dosage units, small batch
Methods. Rapid Microbial Methods (RMMs), such as sizes or limited number of articles in a batch.
those provided by Celsis, are accepted microbiology tests
5
that can be used in lieu of the tests as defined in the USP Determine when and how often to test (i.e. at which
Microbiology Chapters. Those who have implemented such stages within the production process – from raw materi-
alternate methods are unaffected by the changes to the USP. als to finished goods). Given the number of changes to
USP <61> and the addition of USP <62>, it’s important to plan
2
Understand how the new chapters impact the require- ahead not only for the type of analysis to be performed, but for
ments for growth and recovery of specified microorgan- the time and cost required to do so effectively.
isms and specified microorganisms tests. In USP <61> Should the analysis not meet the initial requirements, addi-
(formerly called the Microbial Limits Test, now renamed the tional testing may be necessary which could require extra time.
Microbial Enumeration Test), the most obvious change is the Be sure to build enough flexibility into your schedule to accom-
separation of the Absence of Specified Microorganisms test modate these scenarios, and consider using rapid microbial
into a new chapter, USP <62>. USP <62> is a new chapter that screening methods. Absence of contamination can be deter-
describes the requirements for growth and recovery of speci- mined in 18-24 hours (vs. an average of five days), significantly
fied microorganisms such as Salmonella or S. aureus. Note reducing production cycle times.
that all of the specified microorganism tests have undergone
6
If you outsource to an analytical lab, evaluate how this con- Suitability Test, and they must now specify which microorganisms are
tract facility is meeting the new requirements of USP <61> and required to be absent. The Suitability Test ensures that any antimicro-
the addition of USP <62>. Since significant changes are a result bial activity inherent in the test sample will not adversely affect the
of harmonization with EP methods, contract labs with global custom- reliability of the test.
ers typically have already screened products to the new USP and EP
12
chapters, giving them a head start. Many contract testing labs such as Understand that the specified organisms in USP < 61>
Celsis Analytical Services offer validation services in addition to rou- and USP <62> may not be all inclusive. The organ-
tine analysis to ensure that testing is in compliance with the new har- isms listed in USP <61> and USP <62> are example
monized requirements. Make sure that your lab partner stays abreast organisms. Each user should also consider testing for organisms
of changes in the USP so you can be confident that their services are that are specific to their facility or to their products.
performed according to current pharmacopeial requirements.
FOR MORE INFORMATION
7
If you currently have internal testing methods to screen for con- Download the Celsis White Paper Concerning Changes to USP <61>
tamination and to enumerate specific organisms, consider how and the addition of USP <62> online at
you will need to reconcile your current methods with the USP www.celsis.com/usp.
guidelines. Given the significant changes to USP <61>, if you have your
own methods for testing microbial limits, you need to ensure that they
are fully validated and adhere to updated methods. Remember that the
new USP methods are now more inclusive for more organisms, which
can have an impact on microbiological media used in testing for spe- LESER SAFETY VALVES
cific pathogens, incubation temperatures and duration times.
SINGLE-TRIM DESIGN!
8
Recognize how changes to USP <61> and <62> prohibit retest-
ing and determine how this will impact your operations. Under
the new USP guidelines, retesting of an original sample is not
allowed. However, it is acceptable to perform additional analysis on a
sample that screens positive for contamination using a rapid method.
For this reason, non-destructive rapid testing methods are preferred.
9
Familiarize yourself with the additional organisms that have High Performance,
been specified in the new USP <62>. It’s important to note API Series,
that more organisms have been specified in the new USP Compact Performance,
<62> chapter than in previous USP editions. Organisms such as
Clean Service,
Candida albicans, Clostridia species, and bile-tolerant Gram-negative
Critical Service,
bacteria may be necessary to test for, depending on specific product
formulation and utilization. Modulate Action
10
Recognize how changes to USP <61> and USP <62> alter
incubation times. USP <61> describes microbial enu-
meration tests, which are the plate count procedures for
bacteria, yeast and mould. Although the plate count procedure itself
will not change, the incubation temperatures and times for bacteria
do change slightly. In USP <62>, tests for specified microorganisms are
included. Not only do new modifications change many microbiological
media utilized in testing for specific pathogens, but updates also affect
incubation temperatures and duration.
LESER Safety Valves
11
Understand how updated methodology of the Method for every industrial application
Suitability Test in USP <61> and USP <62> impact the types
of organisms and different growth media that are included.
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to revalidate products to conform to the new USP <61> and <62>
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ith global health and regulatory authorities To satisfy these existing and upcoming compliance man-
continuing to push for tighter regulations dates, avoid costly delays in approval and/or penalties and
surrounding disclosure, transparency and the potential negative impacts to their brand image, life sci-
e-standards, pharmaceutical and other life ences companies must take stock of their existing business
sciences companies are increasingly challenged by frag- processes pertaining to content management and reuse.
mented, quasi electronic, paper-based processes and often These new processes should be enabled through the usage
out-of-date technology systems. Many organizations simply of state-of-the-art system solutions and technologies provid-
lack the process and technology to effectively operate and ing an integrated, collaborative solution across the product
comply in a rapidly changing regulatory environment. The life cycle – from discovery through commercialization.
impact is significant, often translating into costly product Best practices and information technology can play a huge
delays, regulatory fines and lost business opportunities. role here. The right technologies can promote compliance and
Life sciences companies must re-evaluate their existing operational efficiency by automating the transactional tasks
processes and systems and consider new ways to encourage within quality compliance, regulatory affairs and clinical sup-
collaboration, streamline workflow, and keep costs in check to port operations. By automating and streamlining the complex
improve content compliance. Although there are content man- content exchange and submissions requirements throughout the
agement “like” systems, most are “document-centric” and lack product lifecycle, companies can enforce regulatory compliance
the underlying standards-based business intelligence required and automate the many tasks required for clinical trial disclo-
by life sciences companies. In this article, I recommend strate- sure, e-submissions, global labeling, and other standards.
gies and best practices to help life sciences companies manage
and automate these processes to streamline content compli- SIX STEPS TO ENSURE CONTENT COMPLIANCE
ance and reduce development costs while bringing higher qual- WITHIN THE LIFE SCIENCES INDUSTRY
ity products to market faster and more efficiently. 1. Automate process and workflow. If your current
processes are manual or “document centric,” you are vul-
THE COST OF CONTENT COMPLIANCE nerable to errors and discrepancies. You may also lack the
The cost of bringing new drugs to market today ranges ability to easily track history and gain visibility into whether
from $800 million to $1.2 billion and research firm IDC esti- or not a submission is compliant. A two-phase process can
mates that roughly 26% of that cost goes toward the content help you achieve an automated workflow:
requirements associated with regulatory compliance. Phase 1. Look for an easy-to-use content management en-
As the industry and regulators work together to improve vironment that has regulatory guidelines built in. It should
the new drug submission and approval process, there are include an XML-based technology backbone to comply with
a number of different global standards and regulatory man- the new technology mandates for communicating with the
dates such as Clinical Trial Disclosure, Electronic Common regulators during submissions, labeling, disclosure activities
Technical Document (eCTD) and Structured Product Labeling and other forms of interactions. Make sure that the content
(SPL), which life sciences companies must comply with compliance system is designed to manage the entire lifecycle
throughout the product lifecycle. The impact of non-compli- of the regulated content – from internal authoring, review, ap-
ance to these standards is significant and includes costly proval and external communication, to compare, reconcile and
product delays, regulatory fines, and lost market opportuni- maintain regulatory documents going forward. It should also
ties. A current example of regulatory fines is occurring in the be configurable to automatically track milestones and notify
State of Maine, where there is a $10,000 fine per day for non- stakeholders and content contributors when a form has moved
compliance with clinical trial posting rules. Other state, na- (e.g. parent/child relationship tracking) to the next stage in the
tional and international regulatory bodies are enacting their workflow and/or requires an action from them.
own mandates and oversight activities as well. Phase 2. During this phase, the content compliance system
is integrated with your existing information systems automat- 3. Reuse and repurpose content to satisfy global
ing workflow, minimizing data duplication and entry during the requirements. With the advent of common/similar global
present day highly automated regulatory submissions process. regulatory requirements, content management solutions
2. Optimize submissions through collaborative should be viewed in the context of compliance within both
content authoring and review. Traditionally, regulated the U.S. and international regulatory guidelines. To accom-
submission procedures have not been conducive to multiple plish this goal, the content management solution requires a
authors and reviewers. In most cases, a significant amount of level of integrated and configuration capabilities to enable
effort and time is ineffectively spent throughout the process as the compliance objective to be met for the client. Submitting
contributors wait to be emailed their section to add content or information for the same product in multiple countries
review. Then, once that process is completed, the content and should not require you to reinvent the wheel each time to
feedback needs to be compiled, verified and published which ensure compliance with varied submission standards and re-
leads to significant resource efforts and time delays. quirements. Look for a solution that is “standards-ready” and
Ideally, your content system features collaborative author- pre-configured to comply with different global standards and
ing with role-based access control. This enables authorized regulatory mandates such as Clinical Trial Disclosure, eCTD,
authors and reviewers to work on a document simultane- SPL/PLR, and other electronic submissions standards so that
ously, greatly reducing cycle time. Reviewers can simultane- your users can focus on content, and not compliance.
ously add comments for authors allowing all to view their 4. Enable easy adaptation to evolving standards. As
respective comments by tracking their text edits to show regulations continually evolve, in such areas as electronic
their suggested changes – hence streamlining the overall submissions, disclosure standards, labeling the regulatory
process. The technology should automatically facilitate ver- communication process and submissions requirements are
sion control, tracking all changes, so there’s no risk of over- likely to change too. Look for a solution that incorporates
writing another’s work accidentally. In addition, the system FDA and other global requirements and is designed to
should be based in the XML technology while retaining ev- absorb and validate changes as quickly as possible. The
ery detail of revision history in the event of a future change technology should allow you to rapidly add new form fields
or audit. or modify existing ones. In addition, look for a solution that
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5. Evaluate both Software-as-a-Service and perpetual li- part of your users. Many Web 2.0 applications provide familiar, desktop
censing. Look for solutions with flexible delivery options, and conventions and “Microsoft Office®-like” authoring environments.
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license allows for the outright purchase, installation and in-house op- SUMMARY
eration of the software with an annual maintenance fee for upgrades Faced with the daunting challenge of upgrading quasi electronic,
and support; 2) A Software-as-a-Service (SaaS) model allows the pro- fragmented, often paper-based-processes make timely postings, fil-
vider to license the application to the customer for use as a service ings and ongoing regulatory communications nearly impossible. Life
or “on demand” for a monthly fee, eliminating the often large, upfront science companies must look to improved business processes and
costs associated with software purchase and implementation. technologies to comply with the changing regulatory environment.
6. Focus on ease-of-use. Your content compliance solution must ap- The steps recommended above are very practical and achievable
peal to the people that need to use it – business users, managers, regu- strategies to ensure compliance and manage costs in this environ-
latory professionals, clinical staff, etc. As such, your solution should be ment. Each of these strategies can be used individually or in conjunc-
able to work within your existing organizational framework and include tion with others to take greater control of the regulated content life-
cycle. The benefits are multi-dimensional. Streamlining the lifecycle
content management process reduces the risk of delays and poten-
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