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  • 1.  unvalidated drug substance

    This message was posted by a user wishing to remain anonymous
    Posted 02-Oct-2018 14:05
    This message was posted by a user wishing to remain anonymous

    Can you use drug substance that has not gone through process validation to make your finished dosage form submission batches?​


  • 2.  RE: unvalidated drug substance

    Posted 02-Oct-2018 16:41
    If by "submission batches" you mean for use in clinical trials, you have some flexibility.  Suggest you review ICH Q7 Good Manufacturing Practice Guidance for Active Pharmaceutical Ingredients, 09/30/2016 (In FDA Guidance Database), Sect. XIX.F. Validation (19.6).

    If you mean for use for support of an NDA for commercialization, I bet you already know the answer to that!

    All the best,

    Kevin

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    Kevin Daly Consulting, LLC
    kevinedaly@gmail.com

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    Kevin Daly
    Kevin Daly Consulting, LLC
    Encinitas CA
    United States
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  • 3.  RE: unvalidated drug substance

    Posted 02-Oct-2018 21:17
    Are you proposing to use 10% of the proposed full scale production size API to make your drug product for the submission (ANDA or NDA)?

    Are you proposing to manufacture the above pilot scale API (10% of full scale) in the final manufacturing site using production scale equipment?

    Are you planning to validate the API full scale batches once the approval is close or final?

    If the answer to the above three points is "yes"  then it is 'Yes' to your question.

    The risk to the above scenario is 'delayed commercialization ' if the following happens:

    In case you face difficulties when scaling up and require some major CMC changes, then you cannot release the batches to make your commercial drug product batches until the CMC changes for the API are approved. I heard for ANDA, lot of companies manufacture at least one full scale production size batch. You may want to hear from generic ANDA holders on this issue.

    The bottom line is that Validation of drug substance and drug product with full scale batches is a must prior to release to the market once the approval is granted. 


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