Climate change and global warming resulting from greenhouse gas emissions are widely recognized as the biggest threats to global health. The healthcare sector is responsible for 4–5% of global emissions, more than 70% of which are driven by supply chains.
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BioPhorum feedback on ICH Q14 and Q2(R2)
Sep 2022 | Cell & Gene Therapy, Deliverable, Deliverables Report, Feedback to agency, POI - Regulatory, Regulatory, Regulatory Governance
This paper is the BioPhorum response to the recent ICH Q14 and Q2(R2) consultation. Overall, the first-draft guidelines seen by the team need to be less detailed in the main body of the documents but more specific to analytical methods. The documents must also be consistent throughout (across Q14 and Q2 and between the main body texts and examples). Further, detailed examples are needed for modalities other than small molecules (e.g., biologics, cell and gene therapies, etc.) as the small molecule examples are not relevant in some key respects. In the view of the BioPhorum team, the current documents will not drive a consistent understanding of regulatory expectations and the provision of information by industry to regulators.
Webinar PACMPS for LATAM
Jul 2022 | Regulatory
BioPhorum was asked to step in and bring its global collaboration experience to the table in order to pave the way for regulatory harmonization and see greatly shorter timescales for post-approval changes. The webinar communicates post-approval change management protocols for LATAM. Experts in the industry present the principles, process, case studies, and benefits to agencies and patients.The presentation is given in Spanish, slides are...
Industry feedback on ICH harmonized guideline: Continuous manufacturing of drug substances and drug products Q13 draft version
Feb 2022 | Deliverable, Deliverables Report, Drug Substance, Feedback to agency, POI - Regulatory, Regulatory, Regulatory Governance
A comprehensive response to ICH Continuous manufacturing of drug substances and drug products Q13 draft version. The BioPhorum team overall think the draft reads well and believes the concepts and ideas are aligned with BioPhorum thinking on continuous manufacturing for biologic drug substance and drug product.
Industry feedback on USP bioreactivity draft monographs
Jan 2022 | Deliverable, Deliverables Report, Feedback to agency, POI - Regulatory, Regulatory
This BioPhorum paper contains feedback on the USP bioreactivity monographs to plastics used for manufacturing, and the use of resources. It also comments on the potential in vitro tests that should be included, the removal of the implantation test and safety, the removal of Class I to VI, and the topics for omission or inclusion into the <1031> chapter outline. The expert feedback provided in these documents aims to support the USP and, ultimately, produce documents that improve patient safety – but with adequate use of finite analytical resources, which would not be the case with divergent expectations.
Industry feedback on the bacterial endotoxin test (BET)
Jan 2022 | Deliverable, Deliverables Report, POI - Regulatory, Publication, Regulatory
This paper contains feedback on the USP document Bacterial Endotoxin Test (BET): A USP Comparability Study of Recombinant Reagents (Recombinant Factor C and Recombinant Cascade) to Lysate Reagents (LAL). The paper comments on issues such as the feasibility of testing the recommended matrix using four different recombinant reagents and four different lysate reagents, and that water post-deionization (low-purity) but before distillation/ultra-filtration (high-purity) is not representative of samples typically tested for bacterial endotoxins. It also questions whether industry will be able to provide known contaminated samples as these would be difficult to obtain and then compare.
BioPhorum approach to the registration of innovative raw materials using quality by design (QbD) principles
Jan 2022 | Deliverable, Deliverables Report, Drug Substance, POI - Drug Substance, Publication, Raw materials, Regulatory
BioPhorum has defined a best practice approach to the registration of innovative and complex raw materials. The approach is based on quality by design(QBD) principles. It is applicable to different families of non-compendial raw materials in the manufacture of biologics. The approach has already been used by BioPhorum member organizations and accepted by national health authorities.
Industry feedback on ICH Q12: implementation considerations for FDA-regulated products
Oct 2021 | Drug Substance, Feedback to agency, POI - Regulatory, Post Approval Strategies, Regulatory
The aim of ICH Q12 is clearly stated as a framework to facilitate the management of post-approval CMC changes. This document in the industry response to an agency consultation on draft guidance on ICH Q12. The biopharmaceutical industry through these comments commends the agency on leading the way to the implementation of ICH Q12. The BioPhorum comments are heavily influenced by the principle of simplification, which is why our views sometimes differ from the draft guideline.
Regulatory: Feedback to DMKA questions to critical GXP augmented intelligence
Sep 2021 | Feedback to agency, Information Technology, POI - Regulatory, Regulatory
BioPhorum response to work being conducted by The Danish Medicines Agency (DKMA) to define criteria for the application of artificial intelligence (AI) and machine learning (ML) across GxP-regulated areas. The questions asked by the agency considered the requirements and quality of data used to build, test and validate an algorithm, and how it would respond to biases and deviations in results.
An industry reflection on the application of the Russian Pharmacopeia to the registration of biologics
Sep 2021 | Deliverable, Drug Substance, POI - Regulatory, Post Approval Strategies, Publication, Regulatory
In this paper, a BioPhorum member team of experts in biologics and vaccines have summarized the current challenges linked to the registration of global products in Russian Federation. This paper describes some of the challenges faced by the industry in relation to current pharmacopoeial requirements for biologics and vaccines and presents a framework of options and activities that would lead to greater alignment with the ICH and the expectations of other regulatory agencies.