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  • 1.  Cell banks for cell culture process development

    This message was posted by a user wishing to remain anonymous
    Posted 05-May-2020 17:11
    This message was posted by a user wishing to remain anonymous

    Hello,
    one of my technical development colleagues posed this question to me today:

    "Can we use a non-GMP (development) cell bank to do cell culture process characterization for late stage programs? The cell age, cell performance, and product qualities at production stage are comparable to WCB cells."

    I think scientifically the approach can be supported, particularly with summaries of what may/may not be same/different between the development (non-GMP) and product cell banks and risk assessments to review the significance and impact of those differences. The question is more on the regulatory aspect: would the FDA or other authorities have concerns about this approach? Any direct experiences?

    Thanks!



  • 2.  RE: Cell banks for cell culture process development

    Posted 06-May-2020 00:25
    Edited by Yogananth Rajendran 06-May-2020 00:26
    If you have already completed the process characterization with the non-GMP RCB/DCB & intend to use the data for filing, prepare a risk assessment document with the comparison of these banks in 2 levels
    • Comparison of cell bank characterization results.  
    • comparison of CQAs between the material generated from these banks.                                           
    Since you claim "The cell age, cell performance, and product qualities at production stage are comparable to WCB cells." you might be having enough evidence generated between these 2 banks in a qualified scale down model. If not couple of comparative experiments between banks using with SDM will come handy for risk assessment document. 

    We usually got queries on SDM qualifications not to the extent of cell bank used in SDM.

    (Ideally cell culture process characterization for late stage programs should come from a fully characterized cell bank, you must be having the WCB by then.I suggest you to use WCBs if you intend to use the data generated in the characterization to be used for setting up process control strategies that goes in to MA filing. Generally this information will not go in the CTD unless you present the whole scale down model qualification in a signed report form)

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    Yogananth Rajendran
    General Manager Biologics RA
    Ahmedabad
    India
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  • 3.  RE: Cell banks for cell culture process development

    Posted 06-May-2020 13:23
    The short answer is "yes" provided that the development cell bank was the source for the GMP bank and is comparable in terms of performance. However, the devil is in details and you need to evaluate "comparability" carefully between the development bank and the GMP bank with respect to the characterization data you plan to use for, e.g., to support GMP bank for production, etc. Two ICH guidance documents are useful to look at, Q7 Table 1 and Q5D. The US FDA generally follows ICH guidance but EMA guidance is a bit more stringent than ICH in terms of the stage of GMP bank requirements. However, practically EMA is flexible too as long as the manufacturer can appropriately justify a less stringent practice.

    Hope it helps.

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    Jingdong Zhu
    Independent Consultant
    Basking Ridge NJ
    USA
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