Speaking about biologics, I strongly agree with Rachel. At Phase 1, typically assays are "qualified" rather than validated - ie., some initial work has been done to demonstrate that the method is suitable for the intended purpose. Validation typically is performed at or during Phase 2, to be ready for Phase 3, because of the much more intensive effort required.
However, it is important to validate the assay early enough in development - if it fails validation, a new method may need to be identified/developed, and samples from Phase 1 and Phase 2 clinical trial material tested to ensure the material is comparable. Getting the timing right can be especially challenging if you are working on a product that may go from Phase 2 directly to BLA - you'll need to balance the financial and time investment with the potential for delays or additional queries/commitments during review. Risk assessments can help here - it is unlikely that your pH test will fail, for example, but a complex biological potency assay may warrant either earlier validation, or an orthogonal method to test the same characteristic.
Best of luck!
Cathy
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Catherine Anderson PhD, RAC
Associate Director - Regulatory CMC
Hillsborough NC
United States
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Original Message:
Sent: 19-May-2019 16:44
From: Rachel Thornton
Subject: Validated assay
It depends on what you mean by "validated". Assays used for testing of clinical supplies do not have to undergo full ICH validation before commercial manufacture, but you should do some sort of evaluation of the method so that you can be confident of the results. The earlier in development, the looser it can be. European authorities in particular expect to see some kind of "validation data" in the IMPD at least at Ph2. It was highlighted at a CASSS CMC Strategy Forum in Jan 2018 that strictly speaking the assays don't have to be validated until BLA/MAA, but it is STRONGLY RECOMMENDED that the sponsor does so before Ph3/PPQ batches, just because it is a pretty big risk to go through your PPQ and then find out that one or more methods cannot pass validation.
(Speaking for biologicals & biotech products, anyway)
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Rachel Thornton
Associate Director
Smyrna GA
United States
Original Message:
Sent: 17-May-2019 16:32
From: Michael Bui
Subject: Validated assay
Hi,
Does an assay have to be validated in Phase 1 study ? Does a clinical trial assay (CTA) have to be validated ?