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Файл:Ординатура / Хирургия / Библиотека им академика М.И. Перельмана / Книга_5855_Библиотеки_им_академика_М_И_Перельмана.pdf
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- •About the Authors
- •Preface
- •Acknowledgements
- •Contents
- •1.1. Singapore as a British Colony
- •1.5.1. Levelling Up the Pharmaceutical Inspection System of Singapore
- •1.5.2. Advantages of PIC/S Membership to Singapore and Other Participating Authorities
- •1.6. Emergence of MNC Pharmaceutical Manufacturing Industry in Singapore
- •1.6.1. Why do MNC Pharmaceutical Manufacturers Set Up Facilities in Singapore?
- •2.2. Geographical Background of ASEAN vis-à-vis Asia and the Rest of the World
- •2.4. Formation of an ASEAN MRA Taskforce on GMP Inspection
- •2.5. Signing of ASEAN Sectoral MRA on GMP Inspection
- •2.6. Formation of ASEAN JSC on GMP Inspection and Establishing Register of ASEAN LIS
- •2.8. Assessment of FDA Philippines by ASEAN PoE
- •2.9. Register of ASEAN Listed Inspection Services (LIS)
- •3.1. Introduction: Urgency of Training ASEAN Inspectors
- •3.3. Collaboration with Korea Ministry of Food and Drug Safety (MFDS)
- •3.4. Collaboration with the Generics and Biosimilars Initiative (GaBI)
- •3.5. Pre-employment Training in Pharmacy and Pharmaceutical Science Schools
- •4.1. Introduction
- •4.2. Historical Context to WHO Reliance Initiative
- •4.3. The First NRAs to Achieve ML4 and WLA Status
- •4.5. Other International Reliance and Harmonization Initiatives
- •4.5.1. Access Consortium
- •4.5.2. Association of Southeast Asian Nations (ASEAN)
- •4.5.3. East African Community (EAC)
- •4.5.4. European Medicines Agency (EMA)
- •4.5.6. International Council for Harmonization (ICH)
- •4.5.6.1. Introduction
- •4.5.6.2. ICH Members and Observers
- •4.5.6.3. Future Direction
- •4.5.7.1. Introduction
- •4.5.7.2. Addressing Common Regulatory Issues
- •4.5.7.3. ICMRA Pilot Program for Collaborative Hybrid Inspection
- •4.5.8. International Pharmaceutical Regulators Program (IPRP)
- •4.5.9. Latin America
- •4.5.10. Pharmaceutical Inspection Co-operation Scheme (PIC/S)
- •4.5.10.1. Introduction
- •4.5.10.2. PIC/S Participating Authorities
- •4.5.11. WHO Collaborative Registration Procedure for Medical Products (CRP)
- •4.5.12.1. Introduction
- •4.5.12.3. WHO Inspection Report
- •4.5.13. ZaZiBoNa
- •4.6. Conclusion
- •5.1. Introduction to GMP
- •5.2. Overview of the PIC/S GMP Standard
- •5.3. How is an On-site GMP Inspection Conducted?
- •5.3.1. Why is the Warehouse Inspected?
- •5.3.3. Why are the Production Areas Inspected?
- •5.3.4. Why are the Packaging Areas Inspected?
- •5.3.5. Why are the QC Laboratories Inspected?
- •5.3.6. Why do GMP Inspectors Visit Other Miscellaneous Areas?
- •5.3.8. Why is there a Need to Conduct Documentation Audit/Review?
- •5.3.8.1. Assessing Product Quality Review
- •5.3.8.3. Assessing Self-Inspection Program
- •5.4. The 20 Annexes of PIC/S GMP Standard
- •5.5. PIC/S Inspection System: A Risk-based Approach
- •5.5.1. Whom can the GMP Inspector Interview?
- •5.5.2.1. Inspector’s Expectations of a Manufacturer
- •5.5.2.2. Manufacturer’s Expectations of an Inspector
- •5.6. Who Inspects the Inspectors?
- •6.1. Historical Development of Pharmaceutical Quality
- •6.2. What is a High-Quality Medicinal Product?
- •6.3. Purity of a Medicinal Product: Elimination of Impurities and Contaminants
- •6.3.1. What is a Contaminated Medicinal Product?
- •6.3.2. Why is There a Need to Control Impurities?
- •6.3.2.1. Types of Impurities from APIs
- •6.3.2.2. Types of Impurities from Container-Closure System
- •6.3.3. Control of Intrinsic Contaminants
- •6.3.4. Control of Extrinsic Contaminants
- •6.3.5. General Assessment of Cross-Contamination Risks
- •6.4. Stability and Shelf-Life Testing of a Medicinal Product
- •6.4.1. Why is Proper Storage, Distribution and Handling of a Medicinal Product Important?
- •6.6. Summary of High-Quality Medicinal Products
- •7.1. Introduction to Stability and Quality
- •7.3.1. Why is Proper Storage Important?
- •7.3.2. Why is Proper Transportation of a Medicinal Product Important?
- •7.3.3. Why is Proper Handling of a Medicinal Product during Use Important?
- •7.4.1. Number and Size of Batches
- •7.4.2. Testing Frequency
- •7.4.3. Storage Conditions
- •7.4.4. Test Methods
- •7.4.5. Container-Closure Systems
- •7.5. Stability Study Schedule and Report
- •7.6. Temperature Excursions and Product Stability
- •7.8. Cold Chain Products and Temperature Excursions
- •7.11. Conclusion
- •8.1. Christopher Columbus versus the Vikings
- •8.4. Pharmaceutical Data Integrity and ALCOA
- •8.5. Article(s) on Pharmaceutical Data Integrity
- •Introduction
- •Current trends
- •Reasons for Data Integrity violations (inadvertent and intentional)
- •Assuring and promoting Data Integrity via legislation and guidance documents
- •Legislation
- •Guidance documents
- •Proposed Solutions to Better Promote and Assure Data Integrity
- •Culture of integrity
- •Database management systems
- •Robust quality agreements
- •Collaboration between countries
- •Computerized systems validation
- •List of abbreviations
- •Conclusion
- •Authors
- •References
- •9.1. Pharmaceuticals versus Biopharmaceuticals
- •9.2. Transcription and Translation: Central Dogma of Genetics
- •9.3. Biotechnology-derived Medicinal Products: Microbial versus Mammalian Substrates
- •9.4. Manufacture of Biotechnology-derived Medicinal Products: Key Processes
- •Introduction
- •Manufacture of biopharmaceuticals — an overview
- •Procurement and testing of biological starting materials
- •Generation and characterization of cell banks/seed lots
- •Cell culturing
- •Challenges concerning manufacture of biopharmaceuticals
- •Extensive process and product understanding required
- •Inherent variability of host cells
- •Downstream processing remains a key bottleneck
- •Review of current GMP frameworks for biopharmaceuticals
- •Challenges in the regulation of biopharmaceuticals
- •Resource-intensive evaluation of biosimilarity
- •Growing number of data integrity lapses
- •Proposed solutions to challenges of biopharmaceuticals
- •Optimizing biopharmaceutical manufacturing with Industry 4.0
- •Enhancing data integrity with a culture of quality (quality culture)
- •Conclusion
- •List of abbreviations
- •Authors
- •References
- •10.1. Introduction
- •10.2. Advantages of Nanomedicines
- •10.3. Types of Nanomedicines
- •10.3.1. Nanocarrier Systems
- •10.3.2. Nanosuspensions
- •10.4. Future of Nanomedicines
- •10.5. GMP Requirements Governing Nanomedicines and Challenges
- •10.5.1. Lack of Trained Personnel to Operate Manufacturing Processes
- •10.5.2. Lack of Safety Protocol for Manufacturing Personnel
- •10.5.3. Challenges in Controlling for Nanoparticle Contamination
- •10.6. Conclusion
- •11. Novel and Traditional Vaccines
- •11.1. Historical Development and Evolution of Traditional and Novel Vaccines
- •11.2. Traditional Vaccines Versus Novel Vaccines
- •Introduction
- •Traditional vaccines
- •Novel vaccines
- •Vaccine manufacture
- •Vaccine storage, transport and distribution
- •Regulatory controls
- •Challenges, safety and quality issues and possible solutions
- •Conclusion
- •Authors
- •References
- •12.1. Cells and Tissues
- •12.2. Gene Therapy Products
- •12.3. Published Article on CTGTPs
- •Introduction
- •CTGTPs and their principles of action
- •Manufacturing of CTGTPs
- •Premises and equipment
- •Materials and processing
- •Starting material
- •Quality control
- •Cryopreservation
- •Human resource and accreditation
- •Potential solutions to the challenges encountered in manufacturing
- •Outsourcing
- •Technology
- •Control of CTGTPs
- •Current regulatory framework
- •Risk-based approach
- •Conclusion
- •Authors
- •References
- •13. Hand Sanitizers
- •13.1. What are Hand Sanitizers?
- •13.4. Published Article and Commentary on Hand Sanitizers
- •Introduction
- •The microbiology of bacteria, fungi and viruses
- •Antimicrobial compounds and their applications in hand sanitizers
- •FDA policy for testing of alcohol and USP limits for methanol
- •Common myths about hand sanitizers
- •A lack of regulatory framework
- •Proposed solutions
- •Tightening the regulatory framework
- •Training pharmacists on hand sanitizer vigilance
- •Public Education
- •Conclusion
- •Authors
- •References
- •14. Pharmaceutical Dosage Forms
- •14.1. Introduction
- •14.2. What Are Pharmaceutical Dosage Forms?
- •14.4.1. Routes of Administration
- •14.4.1.1. Oral Dosage Forms — Solids
- •14.4.1.2. Oral Dosage Forms — Liquids
- •14.4.1.3. Topical Dosage Forms
- •14.4.1.5. Inhaled Dosage Forms
- •14.4.1.6. Ophthalmic Dosage Forms
- •14.4.1.7. Nasal Dosage Forms
- •14.4.1.8. Otic Dosage Forms
- •14.4.1.9. Rectal Dosage Forms
- •14.4.1.10. Vaginal Dosage Forms
- •14.4.1.11. Transdermal Patch
- •14.4.2. Physical Forms
- •14.4.2.1. Solid Dosage Forms
- •14.4.2.2. Liquid Dosage Forms
- •14.4.2.3. Semi-solid Dosage Forms
- •14.4.2.4. Gaseous or Aerosol Dosage Forms
- •14.5. Manufacture and Important Characteristics of Common Pharmaceutical Dosage Forms
- •14.5.1. Tablets
- •14.5.2. Capsules
- •14.5.3. Solutions
- •14.5.4. Suspensions
- •14.5.5. Emulsions
- •14.5.6. Creams
- •14.5.7. Ointments
- •14.5.8. Metered Dose Inhalers
- •14.6. Overall Summary of the Manufacture of a Pharmaceutical Dosage Form
- •15.1. Introduction

Expedited
pathways
Exempted from
licensing
Authorization
procedure/
comments
US FDA Europe EMA
• Conditional approval
• Fast-track approach
Minimally manipulated, for
homologous use.
Issued the ‘Guidelines for Stem
Cell Research’ in 2017, covering
only research rather than ther-
apeutic applications of stem
cells. There is currently no law
regulating the use of stem cells
and violators are not liable to
punishment
Regulated as a drug. Genetically
modified human cells (Class 4
biologicals) must be submitted
under the CTX scheme, unless
a trial with the same product
for the same indication has
been approved in a comparable
jurisdiction.
Table 5: (Continued)
• Abridged evaluation
• Priority review
• Special Access Route (import, supply)
Minimally manipulated, for homologous use. Class I CGTPs.
For product registration of Class 2 CTGTPs,
the company has to be local and regis-
tered with the Accounting and Corporate
Regulatory Authority (ACRA). Pre-sub-
mission notification must be given to
HSA, and application dossier organized in
ICH/ ASEAN CTD format. Applicants may
choose to have a pre-market consultation
session, to be booked 5 months before the
consultation
Therapy products are eligible for the abridged
evaluation route if it has been approved
by at least a single drug regulatory agency
during submission. For priority review,
the therapy product would have to be used
for serious life-threatening conditions or
disease conditions of local public health
concern.
• Standard review
• Fast-track review
CGTPs are classified as medicinal
products.
Class I CGTPs are not required
to be registered with any
authority but must be written
down at the clinical site of
the healthcare professional,
which must comply with Good
Tissue Practice and the Private
Healthcare Facilities and Ser-
vices Act 1998.
Class II CGTPs have to be
registered with the Drug
Control Authority (DCA), and
the dossier for submission to
be based on the ASEAN com-
mon technical dossier. The
criteria for fast-track review
382
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products

Ref. [35], [72] [1] [7 3]
Thai FDA South Korea
Act/regulation Drug Act B.E. 2510 (1967) and its
amendments.
Expedited
pathways
Exempted from
licensing
• Standard review
• Priority review
• Abridged review
According to the law and regula-
tion, ATMPs require product
registration. They are not
MFDS
Advanced Regen-
erative Medi-
cine, Advanced
Biopharmaceu-
ticals Act
• Priority
Review Process
• Customized
Review System
• Conditional
Approval
Minimal manip-
ulation is per-
formed to the
ICH WHO
— —
— —
— —
include the application of new
research therapy products tar-
geting public health concerns,
with an application evaluation
period of around 22 business
days as compared to 45 business
days in the standard review.
Cells, Tissues, and Gene Therapy Products
(Continued)
383

384
Authorization
procedure/
comments
US FDA Europe EMA
exempt from registration.
Priority review covers
life-threatening medicines
and medicines in urgent need
for public health problems.
Abridged review for new drugs/
biological products using refer-
ence drug regulatory authority
assessment where the product
has already been approved and
sold in the US, EU, United King-
dom (UK), Switzerland, Aus-
tralia, Canada and Japan. Both
priority review and abridged
review are considered under
registration pathway. They are
not exempted from registration
licensing.
Thai FDA Notification on Control
and Regulation of ATMPs as
well as Guideline on advanced
therapy medicinal product
(ATMP): Cell Therapy
Table 5: (Continued)
therapy during
surgical
operation/
treatment at a
medical center.
The Advanced
Biopharma-
ceuticals Act
allows the
separation of
advanced
Gene therapy medicinal
products: ICH guide-
line S12; ICH Consid-
erations — Oncolytic
Viruses
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
INN Nomenclature Scheme for
Cell Therapy Products (CTP).

Medicinal Product was issued
and implemented in 2018.
biophar-
maceutical
products from
the existing
Pharmaceutical
Aairs Act. Key
details include
the definition
of advanced
regenerative
medicine and
advanced
biopharma-
ceuticals and
aim to provide
quick response
to medical
demands while
developing the
biopharmaceu-
tical industry
Quality: Q5B; Q5D; Q5A;
Topic Q5E; 5QC; Q6B;
Q7; Q9; Q10 Ecacy:
E1; E3; E4; E6; E7;
E8; E11
Considerations: General
principles to address
the risk of inadvertent
germline integra-
tion of gene therapy
vectors; General
principles to address
virus and vector
shedding
Cell therapy and tissue
engineering:
Quality: Q2; Q5A; Q5C;
Q5D; Q5E; Q7; Q8; Q9;
Q10
Safety: S6
Ecacy: E1; E3; E4; E6;
E7; E8; E11
Cells, Tissues, and Gene Therapy Products
(Continued)
385

Table 5: (Continued)
US FDA Europe EMA
The product registration of
ATMPs is required. violators
are subject to law punishment.
Manufacturing and/ or import-
ing ATMPs for clinical trial
purpose is exempt for registra-
tion but permission from Thai
FDA is required according to
related Ministerial Notification
and Thai FDA Notification.
Ref. [38] [74] , [75] [76] [4 0]
ASEAN: Association of Southeast Asian Nations; CTGTP: cell, tissue and gene therapy product; FDA: Food and Drug
Administration; HCT/PS: human cells, tissues, and cellular and tissue-based; ICH: International Council for Harmonisa-
tion of Technical Requirements for Pharmaceuticals for Human Use; INN: International Nonproprietary Names; NMPA:
National Medical Products Administration; PMDA: Pharmaceutical and Medical Devices Agency; PRIME: PRIority MEdi-
cines; TGA: Therapeutic Goods Administration.
386
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products

Cells, Tissues, and Gene Therapy Products
to drug withdrawal and subsequently a loss of profit. The postmarketing requirements issued by regulators are also scant on details
[72, 77]. Robust post-market evidence is essential in facilitating the
successful implementation of accelerated approval programmes for
the verification of the safety and ecacy of CTGTPs. However, postmarket studies largely utilize methods similar to pre-market trials
with minimal patient numbers and brief follow-up periods rather
than using real-world scenarios for approved ATMPs in the EU [72,
78]. As such, regulations need to achieve the balance between flexibility in accommodating new knowledge and at the same time specific in terms of setting out requirements in data submission.
In terms of GMP standards, the characteristics of CTGTPs should be
considered, such as smaller batch sizes and shorter half-lives. As such,
it is important to establish GMP standards dierent from conventional drugs and biologicals that account for the inherent variability
of CTGTPs, where out-of-specification (OOS) products may be anticipated. An example would be the approved CAR-T cell therapy product
Kymriah (Novartis), where 10% of products could not be shipped due
to OOS issues or manufacturing failures. However, OOS Kymriah is
still eective with no evidence of higher safety risk as supported by
real-world data [79]. Currently, some countries such as Japan and China
have already started to move towards incorporating real-world data
into submission requirements, evident from China’s ‘Guideline for the
use of Real-World Evidence for Research and Regulatory Review’.
387
International harmonization of definition and
scope of policies
A key discussion in the enactment of Japan’s Act on the Safety
of Regenerative Medicine (ASRM) highlighted the importance of

388
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
shaping the scope of the regulation and deciding what it would regulate, as it could potentially exclude regulation of important developing therapies [80]. The ASRM has also adopted the term ‘regenerative
medicine et cetera’, with ‘et cetera’ providing the flexibility to include
technologies not yet discovered and unapproved therapies [80]. Discrepancies in regulatory terminologies such as the definition of
CTGTPs led to the approval of the same product under dierent definitions. For example, tisagenlecleucel was approved as a cell therapy
product in Australia and Japan yet approved as a gene therapy product in the US and EU [72]. The criteria for eligibility and application
procedures for expedited programmes varied across dierent countries, where no single product was granted expedited approval under
the expedited programmes in the US, EU and Japan [72]. This could
discourage manufacturers from seeking approval in foreign countries as they would need to spend additional resources to maneuver
dierent regulations, thus limiting patients’ access to therapies.
In line with the harmonization of regulations, there is also a need for
greater communication between stakeholders. A study showed that
only slightly more than half of companies in Malaysia understood
the variances in registration requirements between dierent product classes [83]. Using the example of Kymriah, the US FDA required
the product to consist of minimally 80% viable T-cells, dierent from
the 70% which was set during clinical trials. However, real-world
data revealed that patients receiving doses of viability below 80%
also achieved complete response [79]. Thus, there is a need for more
extensive communication between dierent stakeholders, and flexibility in adjusting parameter ranges when more data is received even
after the product has been put out to the market.
Furthermore, no global unified regulatory standards are available as a reference or guidance, especially for countries where the

Cells, Tissues, and Gene Therapy Products
technical reviewers lack experience. Also, there are countries which
still do not have specific legislation for CTGTPs, including the lack
of ethical laws and human rights protection, or having separate
regulatory authorities for clinical trial application and marketing
authorization [71] unlike the US or UK.
As such, there is a need for the convergence of international regulations. Social science research has shown that emerging markets are
stabilized when consumer confidence is boosted through creating
standardized regulations [81, 82]. Currently, international harmonization initiatives, including the Gene and Cell Therapy Working
Group of the International Pharmaceutical Regulators Form (IPRF)
and ICH, are taking place, with the ICH being the primary organization in generating shared technical guidelines to be utilized by
dierent countries in the harmonization process. However, this
requires a long time, which may not be rapid enough in dealing
with the speed of innovation in the CTGTP area. As such, convergence may be a more desirable option, where regulatory requirements align across countries by utilizing internationally recognized
guidance documents [73]. This also provides time for manufacturers
to understand any changes to regulations and to adapt manufacturing processes accordingly. By fostering close international cooperation, less advanced countries can also learn from more advanced
countries without the need to abruptly adopt regulation standards,
since they may not have the capacity to do so currently without
being penalized unnecessarily.
389
Conclusion
CTGTPs are novel therapy products that seek to address unmet
medical needs using materials such as stem cells for a regenerative

390
Manufacture and Supply, Science and Reg ulation Towards High-Qua lity Medicinal Products
eect, or through genetic engineering to improve the ability of cells
to target cancer cells. Types of therapies include autologous therapies, where the starting material is derived from the patient, and
allogeneic therapies, where the starting material is obtained from
healthy donors. CTGTPs also dier from conventional biologicals
in manufacturing process due to their specific characteristics, such
as the need to preserve the quality of the entire cell as compared to
conventional biologicals, where the focus is on the quality of the
therapeutic protein product. Storage, transport and cryopreservation of CTGTPs in the manufacturing cycle are also important since
cells require more extreme cryopreservation temperatures, and
additional heterogeneity has to be managed if the therapy product
is autologous. As a result, a more stringent process is required in the
manufacturing of CTGTPs. Some solutions to the challenges encountered in manufacturing include ensuring appropriate accreditation
of professionals handling CTGTPs, using automation and outsourcing to CDMOs to ensure better compliance to GMP standards.
In CTGTP regulation, jurisdictions have defined and categorized
CTGTPs largely according to the extent of manipulation and whether
it is for homologous use or not, where a larger extent of manipulation requires more stringent regulations. Considering the lack of
data from clinical trials due to small clinical trial groups and disease
severity, many jurisdictions have put in place expedited pathways
to allow products to reach patients faster. In addition, regulations
need to be flexible to accommodate new scientific knowledge as the
CTGTP field advances. The dierent levels of regulation across countries serve as a barrier to manufacturers seeking to export CTGTPs
overseas. In addition, certain countries also do not have specific legislation in place for CTGTPs such as ethical laws and human rights
protection. As such, there is a need for the convergence of international regulations to serve as guidance in drafting new laws and

Cells, Tissues, and Gene Therapy Products
to provide clarity to manufacturers. Many guidance documents are
already available, such as the ‘PIC/S Annex 2A for Advanced Therapy Medicinal Products’ to guide manufacturers, as new scientific
knowledge continues to emerge and evolve. With the help of international organizations, the harmonization of regulations across the
world is slowly beginning to materialize, providing guidance and
greater clarity to countries that lag on regulations. International
harmonization can also minimize the duplication of clinical trials
and streamline the process of granting marketing authorizations for
CTGTPs, thereby fostering innovation. There should also be greater
and more eective communication between the regulator and different stakeholders such as manufacturers, with feedback and some
degree of flexibility incorporated into regulations.
The COVID-19 pandemic has accelerated digital transformation
and exposed weak areas in pharmaceutical supply chains. At the
same time, this has also presented opportunities for manufacturers and regulators to utilize technology to tackle the challenges
of CTGTP manufacturing through new and innovative ways, ultimately improving the accessibility of these ground- breaking medicines to patients.
391
Competing interests: None
Provenance and peer review: Not commissioned; externally peer
reviewed.
Authors
Adjunct Associate Professor Sia Chong Hock, BSc (Pharm), MSc
Christine Koh, BSc (Pharm) (Hons)
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