FDA issues new guidance for changes to disposable manufacturing materials
While the FDA is stepping up inspections of manufacturing sites after Covid-19 caused delays, the regulator has issued new guidance to the industry surrounding changes regarding disposable materials.
The guidance states that any changes to disposable materials used primarily in drug and biological product manufacturing, including at contract manufacturing sites, must “be available upon request during an FDA inspection.”
Manufacturers are also required to document and get approvals for changes in both human and animal drug administration and all disposable materials.
According to the FDA, it has received questions surrounding the limited availability of disposable manufacturing materials, especially when the demand increases around public health events or natural disasters. The availability of disposable materials can become short, affecting the production of drugs and biological products.
The regulator recommends that applicants use science and risk-based principles and refer to current guidelines for the industry to determine the appropriate way to communicate changes to disposable materials in the manufacturing process.
Manufacturers need to report if suppliers changed and if they’re using similar materials that may differ in composition or design. They must also report reductions in the number of materials used and if reusing disposable materials.
The guidance details the potential risks to product quality for the use of the disposables in the manufacturing process including whether a disposable material is used upstream or downstream, the use of redundant steps in the process, whether stability controls meet current regulations, and the extent of existing validation data.
Manufacturers are also advised to consider those factors in determining the risk to product quality for any proposed change.
A comparability protocol (CP) could be used also for making changes to disposables, according to the new guidelines. Applicants can use a CP to obtain feedback from FDA on prospective scientific approaches submitted as part of an original application to speed up post-approval changes. An approved CP can be used as a one-time change or repeatedly for a specified type of change over a product’s lifecycle.
When contacting the FDA about any changes, manufacturers must provide information on the affected products, any proposed changes that could mitigate the effects of the shortage on product quality, other products or manufacturing companies involved and any information related to the potential for or actual drug shortage concerns.