FDA Continues the Discussion on AI/ML

Many of our organizations are somewhere in the journey of using AI/ML some where in the drug product lifecycle, so it is no surprise that the FDA is continuing the dialogue with the recently published draft of “Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products.”

This draft guidance lays out a solid approach by using a risk-based credibility assessment framework to establish and evaluate the credibility of AI models. This involves:

Determining if the model is adequate for the intended use
Defining the question of interest the AI model will address
Defining the context of use for the AI model
Assessing the AI model risk based on model influence and decision consequence
Developing a plan to establish model credibility commensurate with the risk
Executing the plan and documenting results

I think may of us are in the midst of figuring out how to provide sufficient transparency around AI model development, evaluation, and outputs to support regulatory decision-making and what will be found to be acceptable. This sort of guidance is a good way for the agency to further that discussion and I definitely plan on commenting on this one.

FDA Draft Guidance on “Considerations for Complying with 21 CFR 211.110”

Usually I expect the FDA to publish some basic primer material as a webinar, so I was a little surprised when “Considerations for Complying With 21 CFR 211.110” was recently published as a draft. I’ve been rereading it, looking for what is actually worthy of a guidance here, and quite frankly, struggling.

It literally is a refresher course on 21CFR211.110. Maybe I should read it as “No we were serious about ICH Q8 and critical quality attributes.” Or maybe it is just the result of one too many bad Type C meetings lately.

Anyway, good refresher on product quality, in-process controls and samples. Still I think this would be better as a webinar with some graphics. Maybe I’ll better understand why this was published based on what sort of crazy comments are made and I can scratch my head and wonder what shenanigans some of these companies are up to.

FDA Draft Guidance on Protocol Deviations for Clinical Investigations

The FDA has published a draft guidance for “Protocol Deviations for Clinical Investigations of Drugs, Biological Products, and Devices.”

This draft guidance adopts the ICH E3(R1) definitions for protocol deviation and important protocol deviation, providing more standardized terminology, which is a great thing. Avoiding the term “protocol violation”, it primarily uses “protocol deviation” and “important protocol deviation.”

The FDA guidance provides detailed sections on the roles and responsibilities of investigators, sponsors, and IRBs in monitoring, mitigating, and reporting protocol deviations. It as specific recommendations for reporting protocol deviations to sponsors, IRBs, and FDA, including timelines and methods.

It mostly seems a good application of a quality-by-design approach, focusing on critical-to-quality factors and risk-based monitoring for clinical studies. Hopefully it will help clear up confusion in this area.

The Failure Space of Clinical Trials – Protocol Deviations and Events

FDA Nitrosamine Impurities Update

FDA guidance, “Control of Nitrosamine Impurities in Human Drugs,” revises the final guidance of the same name issued on February 24, 2021, by including information about nitrosamine drug substance related impurities (NDSRIs), recommending implementation of new nitrosamine control strategies, and providing an updated timeline for manufacturers and applicants to implement these recommendations.

Nitrosamine impurities are important to control because they are potential human carcinogens. Long-term exposure to these impurities at levels above acceptable limits can increase the risk of cancer. Nitrosamines can be found in various consumer products and the environment, and they have been detected in several pharmaceutical products since 2018, prompting recalls and regulatory actions. A lot of regulatory action. Nitrosamine impurities may be one of the biggest drivers of changes in the GMPs.

Current Regulatory View

Regulators, including the FDA, Health Canada, and the European Medicines Agency (EMA), have been actively working to address the presence of nitrosamine impurities in medications. The current regulatory view emphasizes:

Risk Assessment and Control: Regulatory agencies have established acceptable intake (AI) limits for nitrosamines in drug products. These limits are designed to minimize the risk of cancer associated with long-term exposure to these impurities.
Guidance and Frameworks: Agencies have issued guidance documents outlining frameworks for assessing and controlling nitrosamine impurities. For example, the FDA’s guidance includes recommendations for predicting the mutagenic and carcinogenic potential of nitrosamine drug substance-related impurities (NDSRIs) and provides AI limits based on carcinogenic potency categorization.
International Collaboration: There is significant collaboration among global regulators to harmonize approaches and methodologies for controlling nitrosamine impurities. This includes the adoption of the Carcinogenic Potency Categorization Approach (CPCA) to determine AI limits.
Industry Responsibility: Manufacturers are responsible for understanding their processes to prevent nitrosamine formation and for conducting risk assessments. They must implement control strategies and perform confirmatory testing to ensure that nitrosamine levels remain below the established AI limits.

Regulators are focused on ensuring the safety of pharmaceutical products by controlling nitrosamine impurities through comprehensive risk assessments, setting stringent AI limits, and fostering international cooperation. Companies need to make sure they are ahead of this matter.