Viral Risk Management

While rare, viral contamination events can have severe consequences, potentially impacting product quality, patient safety, and company reputation. And while a consent decree is a good way to grow your skills, I tend to prefer to avoid causing one to happen.

Luckily, regulatory bodies have provided comprehensive guidelines, with ICH Q5A(R2) being a cornerstone document. Let’s explore the best practices for viral risk management in biotech, drawing from ICH Q5A and other relevant guidances.

The Three Pillars of Viral Safety

ICH Q5A outlines three complementary approaches to control potential viral contamination:

  1. Selection and testing of cell lines and raw materials
  2. Assessment of viral clearance capacity in production processes
  3. Testing of the product at appropriate stages for contaminating viruses

These pillars form the foundation of a robust viral safety strategy.

Cell Line and Raw Material Control

  • Thoroughly document the origin and history of cell lines
  • Implement comprehensive testing programs for cell banks, including master and working cell banks
  • Carefully assess and control animal-derived raw materials
  • Consider using chemically-defined or animal-free raw materials where possible
  • Implement stringent change control and quality agreements with raw material suppliers

Viral Clearance Capacity

  • Design manufacturing processes with multiple orthogonal viral clearance steps
  • Validate the effectiveness of viral clearance steps using model viruses
  • Aim for a cumulative viral reduction factor of at least 4 log10 per the USP guidelines
  • Consider both dedicated viral inactivation steps (e.g., low pH treatment) and removal steps (e.g., nanofiltration)
  • For continuous manufacturing, assess the impact of process dynamics on viral clearance

In-Process and Final Product Testing

  • Develop a comprehensive testing strategy for in-process materials and final product
  • Utilize state-of-the-art detection methods, including PCR and next-generation sequencing (NGS)
  • Consider replacing traditional in vivo assays with molecular methods where appropriate
  • Implement a testing program that covers a broad spectrum of potential viral contaminants

Risk-Based Approach

The revised ICH Q5A(R2) emphasizes a risk-based approach to viral safety. This involves:

  • Conducting thorough risk assessments of the entire manufacturing process
  • Identifying critical control points for viral contamination
  • Implementing appropriate mitigation strategies based on risk levels
  • Continuously monitoring and updating the risk assessment as new information becomes available

Prior knowledge, including “in-house” experience, plays a crucial role in viral risk assessment and management for biopharmaceutical manufacturing. Here’s how it can be effectively utilized:

Leveraging Historical Data

  • Review past viral contamination events or near-misses within the organization
  • Analyze trends in raw material quality and supplier performance
  • Evaluate the effectiveness of previous risk mitigation strategies

Process Design and Optimization

  • Apply lessons learned from previous manufacturing campaigns to improve process robustness
  • Use historical data to identify critical control points for viral contamination
  • Optimize viral clearance steps based on past validation studies

Cell Line Susceptibility

  • Use accumulated data on cell line susceptibility to various viruses to inform risk assessments
  • Apply knowledge of cell line behavior under different conditions to enhance contamination detection

Risk Assessment Approach

The risk assessment process should take a holistic approach, focusing on:

  • Raw material sourcing and testing
    • Identifying high-risk materials, especially animal-derived components
    • Assessing chemically-undefined components like hydrolysates and peptones
    • Evaluating materials produced or stored in non-controlled environments
  • Cell substrate selection and characterization
    • Documenting the derivation and source history of the cell line
    • Testing cell banks extensively for adventitious agents
    • Assessing the cell line’s susceptibility to various viruses
  • Process design for viral clearance
    • Designing manufacturing processes with multiple orthogonal viral clearance steps
  • Facility design and operations
    • Implementing robust cleaning and sanitization procedures
    • Ensuring proper facility layout and air handling systems to prevent contamination spread
  • Personnel training and practices
    • Training on proper gowning procedures and personal protective equipment (PPE) usage
    • Policies on illness reporting and exclusion of sick employees from critical areas

Preparedness and Response

While prevention is key, being prepared for a potential contamination event is crucial:

  • Develop a comprehensive viral contamination response plan[6]
  • Regularly practice and update the response plan through mock drills
  • Establish clear communication channels and decision-making processes
  • Prepare strategies for containment, decontamination, and facility restart

Continuous Improvement

Viral risk management is an ongoing process:

  • Stay updated on emerging technologies and regulatory guidance
  • Participate in industry forums and share best practices
  • Invest in employee training and awareness programs
  • Continuously evaluate and improve viral safety strategies

By implementing these best practices and adhering to regulatory guidances like ICH Q5A, we can strive to significantly mitigate the risk of viral contamination. While no approach can guarantee absolute safety, a comprehensive, risk-based strategy that leverages cutting-edge technologies and emphasizes preparedness will go a long way in protecting patients, products, and the industry as a whole.

FDA Inspections – GAO Report

The GAO has published a report on FDA’s Inspections that found a 36% decrease compared to fiscal year 2019 in the number of inspections, partly due to reduced investigator capacity. A piece of information that should surprise noone.

The report highlights a concerning trend in the FDA’s drug inspection workforce. From November 2021 to June 2024, the vacancy rate among investigators who inspect foreign and domestic manufacturers increased from 9% to 16%.

I think we’ve all seen the impact of this. It’s worth spending a little time reading the report.

ISO 8061 Adoption in Pharma

How widespread is adoption of ISO 8601, the standard for date and time formats? Is your company aligned?

I see ISO 8601 widely used in scientific fields, software development, and more and more international correspondence. Yet, I think its fair to say the adoption in pharma has been lacking. So I am really curious, has your organization fully or partially adopted it? If so, how did it go?

Date Format

The basic principle of ISO 8601 for dates is to represent them in a descending order of significance:

  • Complete date: YYYY-MM-DD (extended format) or YYYYMMDD (basic format)
    Example: 2022-09-27 or 20220927
  • Year and month: YYYY-MM
    Example: 2022-09
  • Year only: YYYY
    Example: 2022

Time Format

ISO 8601 defines the following time format:

  • Basic format: Thhmmss
  • Extended format: Thh:mm:ss

Where:

  • T is the time designator
  • hh represents hours (00-24)
  • mm represents minutes (00-59)
  • ss represents seconds (00-60, where 60 is used for leap seconds)

Example: T134730 or T13:47:30 represents 1:47:30 PM

Combined Date and Time

ISO 8601 allows combining date and time representations:

  • YYYY-MM-DDThh:mm:ss or YYYYMMDDThhmmss

Example: 2022-09-26T07:58:30 represents September 26, 2022, at 7:58:30 AM

Time Zone Designators

The standard also specifies how to represent time zones:

  • Z: Represents UTC (Coordinated Universal Time)
  • ±hh:mm or ±hhmm: Represents the offset from UTC

Example: 2022-09-07T15:50+00:00 or 2022-09-07T15:50Z represents 3:50 PM UTC on September 7, 2022.

Key Features

  1. The standard uses the Gregorian calendar.
  2. It employs a 24-hour clock system.
  3. All elements are represented by a fixed number of digits, zero-padded if necessary.
  4. The standard allows for reduced precision by omitting certain elements.
  5. It can represent dates, times, time intervals, and recurring time intervals

Government and Official Use

Many countries have officially adopted ISO 8601 as their recommended or mandated date format for government and official use. For example:

  • The UK government has mandated the use of ISO 8601 for IT systems, APIs, and machine-to-machine communication.
  • Canada’s government and Standards Council officially recommend ISO 8601 for all-numeric dates.
  • Australia recommends ISO 8601 as the short date format for government publications.

The European Union has adopted ISO 8601 as the European Standard EN 28601, making it valid in all EU countries.

Has anyone seen Health Canada or an EMA (and/or national competent authority) push back at a time/date not in ISO 8061 format? I think there has been a lot of push back in health care around adoption, for example the NHS in the UK uses 01-JAN-2017 for medicine labels even though the UK has adopted ISO 8061.

I find it fascinating that the eCTD specification does not mandate a specific date format for metadata or content within submissions, allowing flexibility for regional requirements. Yet we have seen many health authorities that have implemented eCTD do recommend or require the use of ISO 8601 date formats in certain contexts:

  • The US FDA guidance on eCTD recommends using ISO 8601 format (YYYY-MM-DD) for dates in the submission.
  • The EU guidance on eCTD also recommends ISO 8601 format for dates in certain metadata fields.

The eCTD XML backbone uses the W3C XML Schema date and dateTime datatypes, which are based on ISO 8601 formats. While not explicitly requiring ISO 8601, the eCTD specification does emphasize the importance of consistent and unambiguous date representations, which aligns with the goals of ISO 8601. It really makes me wonder when this decision will start rippling through other parts of the industry.

I’d love your thoughts.

Preparing your BCP for Trump’s Attacks on Immigration

Time (maybe past-time) to evaluate your organization’s business continuity plan and anticipate the potential actions against immigrants, in particular the potential impact of Trump’s proposed immigration policies on the facility cleaning industry, particularly cleanrooms, which could be significant.

Labor Shortage

The cleaning industry, including cleanroom maintenance, heavily relies on immigrant labor. A mass deportation policy could lead to:

  • Significant workforce reduction: Many cleaning companies employ immigrant workers, both documented and undocumented. A large-scale deportation could severely reduce the available workforce.
  • Increased labor costs: With fewer workers available, companies may need to offer higher wages to attract and retain employees, potentially increasing operational costs.

Industry Disruption

The cleanroom industry, which requires specialized skills and training, could face particular challenges:

  • Loss of experienced workers: Cleanroom maintenance requires specific knowledge and expertise. Deporting experienced workers could lead to a skills gap in the industry.
  • Reduced productivity: As companies struggle to replace deported workers, there might be a temporary decrease in productivity and quality.
  • Increased costs for clients: Higher labor costs in the cleaning industry could be passed on to clients, potentially affecting industries that rely on cleanroom facilities, such as pharmaceuticals and electronics manufacturing.

Actions to Evaluate

Time to evaluate internal training programs to quickly upskill current and new workers, particularly for specialized cleanroom maintenance. Be prepared for the need to have your staff step in and clean, on the moment’s notice. This is a key action to have in the business continuity plan, and frankly should already be there.

Compliance and Legal Challenges

Beyond that, companies should be evaluating their other plans with broad stakeholders like HR and legal for when law enforcement comes calling as a result of heightened enforcement and audits of cleaning companies to ensure compliance with immigration laws. Remember these cleaners work side-by-side with your staff and quite frankly, are really hard to tell the difference. Are you prepared to side with law enforcement, or delay law enforcement? What is your risk tolerance for navigating the complex legal situations, particularly if long-term employees are suddenly subject to deportation?

While the full extent of the impact remains uncertain, Trump’s proposed immigration policies could significantly disrupt the facility cleaning industry, which will greatly impact every manufacturing site I know. The industry may need to adapt quickly to potential labor shortages, increased costs, and changing regulatory landscapes, while navigating the thorny ethical considerations.

No time like the present to start.

Best Practices for Managing the Life-Cycle of Single-Use Systems

Single-use systems (SUS) have become increasingly prevalent in biopharmaceutical manufacturing due to their flexibility, reduced contamination risk, and cost-effectiveness. The thing is, management of the life-cycle of single-use systems becomes critical and is an area organizations can truly screw up by cutting corners. To do it right requires careful collaboration between all stakeholders in the supply chain, from raw material suppliers to end users.

Design and Development

Apply Quality by Design (QbD) principles from the outset by focusing on process understanding and the design space to create controlled and consistent manufacturing processes that result in high-quality, efficacious products. This approach should be applied to SUS design.

ASTM E3051 “Standard guide for specification, design, verification, and application of SUS in pharmaceutical and biopharmaceutical manufacturing” provides an excellent framework for the design process.

Make sure to conduct thorough risk assessments, considering potential failure modes and effects throughout the SUS life-cycle.

Engage end-users early to understand their specific requirements and process constraints. A real mistake in organizations is not involving the end-users early enough. From the molecule steward to manufacturing these users are critical.

    Raw Material and Component Selection

    Carefully evaluate and qualify raw materials and components. Work closely with suppliers to understand material properties, extractables/leachables profiles, and manufacturing processes.

    Develop comprehensive specifications for critical materials and components. ASTM E3244 is handy place to look for guidance on raw material qualification for SUS.

    Manage the Supplier through Manufacturing and Assembly

    Implementing robust supplier qualification and auditing programs and establish change control agreements with suppliers to be notified of any changes that could impact SUS performance or quality. It is important the supplier have a robust quality management system and that they apply Good Manufacturing Practices (GMP) through their facilities. Ensure they have in place appropriate controls to

    • Validate sterilization processes
    • Conduct routine bioburden and endotoxin testing
    • Design packaging to protect SUS during transportation and storage. Shipping methods need to protect against physical damage and temperature excursions
    • Establish appropriate storage conditions and shelf-life based on stability studies
    • Provide appropriate labeling and traceability
    • Have appropriate inventory controls. Ideally select suppliers who understand the importance of working with you for collaborative planning, forecasting and replenishment (CPFR)

    Testing and Qualification

    Develop a comprehensive testing strategy, including integrity testing and conduct extractables and leachables studies following industry guidelines. Evaluate the suppliers shipping and transportation studies to evaluate SUS robustness and determine if you need additional studies.

      Implementation and Use

      End users should have appropriate and comprehensive documentation and training to end users on proper handling, installation, and use of SUS. These procedures should include how to perform pre-use integrity testing at the point of use as well as how to perform thorough in-process and final inspections.

      Consider implementing automated visual inspection systems and other appropriate monitoring.

      Implement appropriate environmental monitoring programs in SUS manufacturing areas. While the dream of manufacturing outdoors is a good one, chances are we aren’t even close yet. Don’t short this layer of control.

        Continuous Improvement

        Ensure you have appropriate mechanisms in place to gather data on SUS performance and any issues encountered during use. Share relevant information across the supply chain to drive improvements.

        Conduct periodic audits of suppliers and manufacturing facilities.

        Stay updated on evolving regulatory guidance and industry best practices. There is still a lot changing in this space.