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332 Z. Rahman et al.
(Fig. 10.1e). The binder can be added in powder formulation and later activated by the solvent, or it can be dissolved directly in the solvent followed by spraying over the powder bed. Thus, BJ is not suitable for printing water-sensitive drugs. Currently available printheads cannot handle highly viscous polymer solutions; therefore, either polymer concentration should be kept low or an organic solvent should be used for high polymer concentration or high-molecular-weight polymers. In the latter case, the printhead should be carefully selected as not all printheads can handle organic solvents. Drying in an oven at 50–60
◦
C or vacuum is required to remove the solvent followed by sifting of the support powder from the printlets (Rahman et al.
2018).
10.2.5 Selective Laser Sintering (SLS)
This method is very similar to BJ, but instead of liquid binder/solvent, it uses heat and laser sintering for powder fusion. It was invented by Carl Deckard and Joe Beaman of the University of Texas at Austin in mid-1980 (Rahman et al. Charoo et al.
2020). Powder components are preheated in the printing platform
followed by powder layering and laser sintering of the selected region of the powder bed as defined by the printer software. Laser sintering causes softening and melting of powder components. This is followed by platform downward movement, powder layering, and laser sintering. This process is repeated till 3D object forms. The purpose of preheating is that it reduces the laser power requirement needed for sintering and melting of the powder components (Fig.
10.1f). Unlike other 3D
printing methods (SLA and BJ), SLA does not require post-processing steps such as drying or UV curing. This method, like FDM and MED methods, is limited to thermally stable components and also requires thermoplastic polymer to bind the powder components. Additionally, laser-absorbing agents such as dye are required to aid in sintering process since pharmaceutical powders are white in color that are inherently poor light absorbers (Charoo et al.
2020).
2018,
10.3 3D Printed Drug Product Development Considerations
10.3.1 Excipient Selection
Excipients play a critical role in providing framework and essential properties to traditionally manufactured dosage forms. These agents function as diluents, binders, disintegrants, lubricants, glidants, extended-release agents, etc. The FDA lists excipients that can be used in drug products in the IIG and GRAS databases (Rahman et al. data for new excipients proposed for use in drug products (FDA also provide the skeleton to 3D printed dosage forms. However, 3DP processes may need additional or specialized classes of excipients that are not typically required in traditional pharmaceutical manufacturing.
2018, Charoo et al. 2020). The agency requires extensive safety
2005). Excipients
10 Regulatory Perspective of Additive Manufacturing in the Field . . . 333
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In SLA printing process, liquid excipients are incorporated into the delivery system by photopolymerization, initiated by UV light. The liquid formulation contains photoinitiators and oligomers besides other components. Photoinitiators absorb incident UV light and trigger the formation of free radicals that react with the oligomers, thus promoting the development of chemical bonds between polymer chains. Key characteristics such as solubility, stability, absorption spectrum, molar absorptivity, and efficacy in generating free radicals are essential properties that should be considered while selecting photoinitiators. Photoinitiators used in drug delivery are Irgacure 819, phenylbis(2,4,6-trimethylbenzoyl) phosphine oxide, diphenyl(2,4,6-trimethylbenzoyl) phosphine oxide, ethyl(2,4,6-trimethylbenzoyl) phenyl phosphinate, etc. (Xu et al.
2021). Oligomers serve as precursors of
photopolymerization. They are synthesized by including vinyl group into the backbone of natural or synthetic polymers via chemical modification with acrylates, methacrylates, fumarates, and vinyl esters. In this regard, the reactivity of acrylates is highest among all the oligomers. Examples of monomers/oligomers used in pharmaceutical applications are tert-butyl acrylate, di(ethylene glycol) diacrylate, (methacryloxypropyl)methylsiloxane, poly(mercaptopropylmethylsiloxane-co­dimethylsiloxane), vinyl terminated polydimethylsiloxane, Pluronic F127 dimethacrylate macromonomers, soybean oil epoxidized acrylate, methacrylated vanillin, acrylated waste cooking oil, methacrylic anhydride, methacrylated vanillin, glycerol dimethacrylate, etc. (Xu et al.
2021). So far, the FDA has not approved any
photoinitiator or oligomer for drug product. One of the reasons is their safety. The majority of photoinitiators and oligomers do not polymerize completely, leaving residue in the delivery system that may be released after ingestion and can produce undesirable adverse effects (Pereira and Bártolo
2015,Xuetal. 2021).
Thermal processes such as HME and spray drying are commonly used to prepare amorphous solid dispersion. Polymers, preferably thermoplastic forms, are required to convert crystalline drugs into amorphous forms. FDM and MED thermal processes can utilize currently available polymers with known safety profile and thus avoid regulatory hurdles. Polymers investigated for drug delivery using FDM process are polyvinyl alcohol, polyvinylpyrrolidone (PVP), polycaprolactone,
Eudragit ypropyl methylcellulose (HPMC), hydroxypropyl methylcellulose acetate succinate
(HPMCAS), Kollidon
®
, polylactic acid, polyethylene glycol, hydroxypropyl cellulose, hydrox-
®
, Soluplus ® , Polyox ® , and ethyl cellulose. Additional excip­ients such as plasticizers, diluents (mannitol, lactose, tricalcium phosphate), and disintegrants (sodium starch glycolate, croscarmellose, crospovidone) may also be required to modulate the process and attain the desired release profile (Cailleaux et
al.
2021). Similarly, Eudragit ® , HPMCAS, and Kollidon ® VA 64 polymers have
been reported for MED process to provide zero-order release delivery systems (Zheng et al.
2021).
BJ process is similar to traditional wet granulation process where solvent or binder solution is added to the powder bed to bind the particles, resulting in an increase in particle size and density and an improvement in dose uniformity. Excipients that have received FDA approval for human use are useful in wet granulation process. They can also be used in BJ process removing any safety and
334 Z. Rahman et al.
regulatory concerns. BJ requires various excipients including diluents, flow promo­tors (lubricant, glidant), binders, humectants, and surfactants. High-dose drugs may
constitute a significant portion of the formulation. For example, Spritam
®
contains 250–1250 mg of levetiracetam. Lactose, mannitol, sucrose, dextrin, microcrystalline cellulose, and pregelatinized starch have been investigated as diluents for the BJ process (Yu et al.
2009, Tian et al. 2019, Wilts et al. 2019). HPMC, sodium
carboxymethylcellulose, ethyl cellulose, and PVP have been explored as binders in both solvent systems and powder mixtures (Yu et al. Kozakiewicz-Latała et al.
2022). Glidants/lubricants (magnesium stearate, talc, and
2009, Tian et al. 2019,
colloidal silicon) facilitate the uniform spread of the powder mixture over the building platform and are used in low percentage (Yu et al.
2009, Hong et al. 2021).
The solvent system can be aqueous, organic, or hydro-organic. Organic solvent allows the use of a high percentage of binder in the solvent system. However, not all BJ printers are equipped to handle organic solvents, and additionally, presence of the residual organic solvents in final printed dosage forms would impact quality and safety. Water and ethanol are commonly used solvent systems for BJ. BJ process may need additional excipients such as humectants and surfactants. Both are typically added to the binder/solvent system. Humectant prevents/slows down the evaporation rate of binder in the printhead and powder bed and keeps the powder bed in a non-dried condition so that it can fuse with successive layer to an appreciable
level. Glycerin is used as a humectant in Spritam
®
tablets. Surfactants are usually required in low concentration and also added to the binder system/solvent system to reduce surface tension and thus prevent clogging of the printhead. Commonly used surfactants are Tween 80, polyethylene glycol 400, and sodium dodecyl sulfate (Tian et al.
2019, Kozakiewicz-Latała et al. 2022). Like in the case of BJ process
seen above, excipients commonly used in wet granulation can also be used in SSE process. SSE involves the extrusion of a paste mixture containing a drug, excipients, and binder (Seoane-Viaño et al.
2021).
Similar to FDM and MED, HME thermoplastic polymer can also be used in the SLS process. Additionally, excipients such as lubricants/glidants form an important part of the formulation composition to facilitate uniform powder spread (Hamed et al.
2021a, b). Fusion of particles takes place by the synergic action of heating
and laser scanning. Initial heating of powder raises the temperature just below the melting point of the powder bed. Laser scanning causes sintering and melting of powder components depending upon their melting point. Thus, the laser provides additional heat to raise the temperature of selected regions of the powder bed. SLS process needs a new class of excipients not used in conventional pharmaceutical manufacturing called laser-absorbing agents. These agents are typically coloring agents and are used up to 3% level. FDA-approved FDC dyes (metal oxide or lake
dyes or synthetic dyes) can be used in the SLS process. Candurin
®
gold sheen (silicon dioxide coated with ferric oxide) is the most commonly reported laser­absorbing agent in the literature for printing dosage forms by the SLS process (Charoo et al.
2020, Hamed et al. 2021a, b).
10 Regulatory Perspective of Additive Manufacturing in the Field . . . 335
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10.3.2 Drug Properties
Various drugs have been printed into immediate- and extended-release systems. Physicochemical properties of a drug influence the selection of excipients as well as the printing method and process parameters. Among the physicochemical properties, stability is of paramount importance. Ideally, a drug should be stable against all external factors such as temperature, oxidation, light, and solvent (Rahman et al.
However, a drug may rarely exhibit stability against all risk factors; as a result, a process is chosen to ensure that the drug retains its stability characteristics. FDM and MED are not suitable for thermally labile drugs. Similarly, SLA printing process requires that a drug possesses stability against UV light. Both thermal and light stability are required for drugs intended to be printed using the SLS process. BJ and SSE processes expose the drug candidate to solvent-mediated hydrolysis. Another property to consider in process selection is solubility of the drug in oligomer, especially in the case of SLA printing as liquid oligomer is printed into dosage forms. Solubility of drugs in the oligomer and photoinitiator solutions would ensure uniformity of drug content in the final printed dosage forms. Insoluble drugs are not ideal candidates for the SLA process (Rahman et al. et al.
2021).
2018, Charoo et al. 2020).
2018, Charoo et al. 2020,Xu
10.4 Process Design and Process Understanding
Product design is dictated by 3DP process and material attributes. Furthermore, each 3DP process adds distinct features to the printed delivery system. For example, BJ printed dosage forms are usually very porous and dissolve instantly without water or a sip. The first FDA-approved 3DP product was a high-dose product that disintegrated in 2–11 s. On the other hand, FDM, SLS, MED, and SLA printed dosage forms will have moderate-to-high mechanical strength compared to BJ printed products. Generally, all the 3DP methods are amenable to developing sustained-release delivery systems, except BJ. In addition to the above-listed factors, designing a dosage form also depends upon the components of the formulation such as drug, excipients, and polymer attributes besides process parameters (Rahman et al.
2018, Charoo et al. 2020).
Development of quality 3D printed products depends upon the understanding of critical material attributes (CMAs) and critical process parameters (CPPs) and how their interactions impact critical quality attributes (CQAs) of printed dosage forms. ICH guidance documents that Q8 and Q9 can be used as a framework during product development. These guidelines emphasize on built-in quality rather than testing drug product for quality. Quality by design (QbD) is an approach to build quality into the product (ICH and manufacturing processes should be investigated, and control strategy should be developed to consistently produce a quality product. In general, CMAs and CPPs are identified through an assessment of the extent to which their variation can have
2005,ICH2009). Attributes of drug substances, excipients, polymers,
336 Z. Rahman et al.
Table 10.1 Critical material attributes and process parameters of various 3D printing processes
3D printing process Critical material attributes Critical process parameters
Stereolithography Viscosity, surface tension, etc. Layer thickness
Fused disposition modeling
Binder jetting Powder: Particle size distribution,
Selective laser sintering
Filament dimeter, amorphous/crystalline ratio, elasticity, plasticity, viscosity, melting point
bulk and tapped densities, shape, size, cohesiveness, moisture content, porosity, flow behavior, wettability, etc. Liquid: Surface tension and viscosity
Particle size distribution, bulk and tapped densities, shape, size, cohesiveness, porosity, moisture content, flow behavior
Laser exposure time/speed Laser angle Laser spot diameter Orientation Curing depth Hatch spacing Fill cure depth UV wavelength Post-cure time temperature
Extrusion temperature, extrusion speed Layer thickness Number of printheads Percentage fill Print pattern Print nozzle diameter Print-bed temperature Raster thickness Raster gap width Raster angle Build orientation Rate of cooling
Number of printheads Spraying mechanism Bed temperature Binding jetting pattern Binder delivery rate Powder spread speed Layer thickness Post-processing heat-curing parameters (curing method, temperature, and time)
Laser energy density Laser spot diameter Laser angle Bed temperature Layer thickness Hatch distance
an impact on the CQAs of the drug product. CMAs and CPPs vary with the 3DP process and dosage form being printed. CMAs and CPPs of 3DP are listed in Table
10.1. Various tools are available to understand CPPs, CMAs, and CQAs (Barakh Ali
et
al. 2019). These are formal experiment design and process analytical technology
(P
AT).
Formal experiment design and process monitoring tools can be employed to f
asten product development. Both components are part of the QbD approach
10 Regulatory Perspective of Additive Manufacturing in the Field . . . 337
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advocated by the FDA. Formal design of experiments allows understanding of the impact of CMAs and CPPs on CQAs. PATs are process monitoring tools for understanding, monitoring, and controlling the process. It is defined as the system for “designing, analyzing, and controlling manufacturing through timely measurements (i.e., during processing) of critical quality and performance attributes of raw and in-process materials and processes, with the goal of ensuring final product quality” (FDA
2004). The term “analytical” means chemical, physical,
microbiological, mathematical, and risk analysis conducted in an integrated manner. The objective of PAT measurement is to enhance understanding and control of the manufacturing process. PAT tools are commonly used to monitor unit operations of traditional pharmaceutical manufacturing processes such as mixing, milling, granulation, hot-melt extrusion, tableting, coating, and spray drying (Zidan et al.
2010, Markl et al. 2013, Kim et al. 2021). These tools allow monitoring of each
individual process unit to ensure that the end point of the process has been achieved before transferring in-process material into the next unit operation, e.g., mixing, granulation, or drying. Additionally, these allow real-time release of the batch subject to mandatory validation requirements having been fulfilled. PAT tools can also be used for 3DP processes. Monitoring of 3DP process is required since the process is continuous in nature as there is no feasibility for in-process material sampling. However, challenges remain as to how PAT sensors can be installed to monitor 3DP process. 3DP is a dynamic process as the dimension of the dosage form continuously changes during the manufacturing, which further complicates monitoring and data analysis. Interference between sensor and printhead such as laser/UV scanning is likely to be encountered in 3DP. The software would need to be programmed in such a way that there would be a delay or time gap between layer scanning and monitoring. In contrast, in traditional manufacturing, multiple sensors can be installed in a unit operation without technical difficulty or interference. The most commonly used PAT tools are near-infrared sensors and Raman spectroscopy (Fig.
10.2). These PAT tools can provide useful information on physical and
chemical transformations occurring during the printing process including particle size, moisture content, assay, impurity, polymorphic transformation, etc. (Zidan et al.
2011, Rahman et al. 2013a, b). In the case of 3DP, spectra of each layer can
be linked to the CQAs of the dosage form. Off-line sensors have been reported for monitoring the quality of the printlets and amorphous-to-crystalline quantification (Hamed et al.
2021a, b).
10.5 Challenge in 3D Printing Processes
10.5.1 In-process Sampling
Traditional processes are multistep processes where discrete unit operations are performed in a systemic order. At the beginning of each unit operation, processed material from the previous unit operation is tested before proceeding to succeeding operation. For example, water content is tested in dried granules before lubrication
338 Z. Rahman et al.
Fig. 10.2 3D printing process monitoring by PAT sensors
unit operation. On the other hand, in-process sampling and testing are not feasible in 3DP process, as finished dosage form is formed in a single-unit operation in a continuous fashion. However, filament, paste, or powder mixture consisting of drug(s) and various excipients can be tested before and after printing to ensure that there is no change in the quality attributes of raw material during the printing process. This will provide some confidence about the quality of the printed dosage forms.
10.5.2 Recycling
Not all raw formulation composition is utilized in printing dosage forms. For example, powder mixture in SLS and BJ processes provides support to the printed dosage forms and is retrieved at the end. In the case of SLA, the printed dosage form is printed in vat that contains liquid mixture, i.e., drug dissolved in initiator and oligomer. However, some 3DP processes print all the raw formulation composition and hence prevent material loss. Examples of such 3DP processes are FDM, MED, and SSE. Unprinted powder presents challenge in reutilizing it in printing subsequent dosage forms as processing can adversely affect CQAs of the powder formulation. In BJ process, the binder/solvent spread with subsequent diffusion over the powder bed. Solvent/binder may spread laterally beyond the desired region of the powder. Similarly, laser light may stray and scan undesired region of the powder in the case of SLS. In the case of SLA process, UV-mediated polymerization may also change the composition of liquid. The CQAs of unprinted powder or liquid mixture that may change after exposure to process cycles include change in impurities,
10 Regulatory Perspective of Additive Manufacturing in the Field . . . 339
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particle size distribution, moisture content, polymorphic transformation, and change in polymorphic content. These changes may or may not have a significant impact on the CQAs of the printed dosage if used as such. The unprinted raw material can be discarded, reused, or recycled. If reused, its effect on the CQAs of the dosage forms should be evaluated prior to its use. Another option is to recycle it in such a way that exposed raw material can be mixed with the virgin powder in a certain proportion. However, caution should be exercised while empirically determining the number of reuse cycles for powder or percentage of exposed powder that can be mixed with virgin powder while still producing dosage forms meeting their CQAs (Rahman et al. the literature on this subject. Recently, Khuroo et al. (
2018, Charoo et al. 2020). There is not much information available in
2022) demonstrated a change
in powder mixture characteristics after exposure to SLS process.
10.5.3 Stability
As mentioned earlier, drugs or excipients that can be processed via 3DP must possess certain physicochemical characteristics. For instance, thermal stability is required for FDM, MED, and SLS, while aqueous/solvent stability is required for BJ and SSE processes. Likewise, photostability is required for printing dosage forms using the SLA process, while SLS process requires drugs and excipients to exhibit adequate thermal and photostability. Heat, laser, and/or solvent may induce chemical and/or physical transformation in drugs and excipients that may be reflected in the change in quality attributes of the printed dosage forms. Khuroo et al. (
2022) reported no change in CQAs of isoniazid printlets after exposure to
◦
C/75% RH in a pharmacy vial (Khuroo et al. 2022).
40
10.5.4 Amorphous-to-crystalline Transformation
Most of the drugs exist in crystalline form, and very few drugs are present in an amorphous form in their native state, e.g., vancomycin hydrochloride (Rahman et al. 2013a, b). Amorphous form is preferred for biopharmaceutical reasons due to better dissolution and bioavailability. However, the amorphous form is thermodynamically unstable and may revert to stable crystalline form when exposed to high temperatures and humidity (Dharani et al. Unlike traditional manufacturing methods, many 3DP methods provide a single-step process to fabricate amorphous solid dispersion dosage forms, e.g., FDM, MED, SLA, and SLS. Heat or laser converts crystalline drug in situ into an amorphous form, which is stabilized to a certain extent by the polymer matrix (Rahman et al.
2018; Charoo et al. 2020). Depending upon the drug properties and excipients
present in 3D printed dosage forms, drug may or may not transform back into crystalline form on exposure to temperature and humidity. Hamed et al. ( reported less than 5% crystalline conversion of amorphous printlets of lopinavir after exposure to 40
◦
C/75% RH for a month in pharmacy vials (Hamed et al. 2021a, b).
2021, Hamed et al. 2021a, b).
2021a, b)
340 Z. Rahman et al.
10.5.5 Regulatory Nomenclature
Dosage forms’ name is typically derived from the manufacturing process. For example, a compressed dosage form is called a tablet, and granules or powder filled in hard gelatin capsules is categorized as a capsule dosage form. These terms are accepted by all regulatory agencies. However, there is no regulatory consensus on
an acceptable term for 3DP printed dosage form. Spritam
®
did not get a special name that would indicate that it is fabricated by the 3DP process. Its label says “tablet for oral suspension.” Not all health professionals are aware of the advantage offered by
Spritam
®
over the traditionally manufactured dosage forms of levetiracetam due to its unique manufacturing method. On the other hand, literature uses different terms for 3DP dosage forms. The most commonly used term is printlets, but this is not a regulatory acceptable term (Hamed et al.
2021a, b).
10.5.6 Volume
Thousands of capsules and tablets can be manufactured in an hour using traditional manufacturing methods. Even though 3DP processes involve fewer manufacturing steps compared to the traditional manufacturing methods, current 3DP methods allow the manufacturing of only a few hundred dosage forms in an hour. Although production volume can be increased by increasing the number of printheads, still production volume cannot compete with the traditional manufacturing methods. Currently, 3DP processes are therefore more suited for printing specialized dosage forms where volume is not a critical consideration, such as implants, anticancer drugs, or orphan classes of drugs (Rahman et al.
2018, Charoo et al. 2020).
10.5.7 Quality Defects
Quality defects in a dosage form arise due to formulation- and/or process-related factors. Most of the defects are cosmetic in nature, which means that they will not impact in vitro and the clinical performance of the dosage forms. Defects reported for tablets include sticking, mottling, delamination, etc. Similar to traditional dosage forms, many defects are reported for 3D printed dosage forms. These include cor­ners or elephant’s foot, shrinkage, warping or bending, coffee stain effect, staircase effect/layer shifting, delamination/Z-layer separation, balling, weight variation, etc. Weight variation and delamination may impact CQAs where patients may not get the required dose. These defects are attributed to the poorly designed formulation and/or process parameters (Rahman et al.
2018, Charoo et al. 2020).
10 Regulatory Perspective of Additive Manufacturing in the Field . . . 341
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10.5.8 Packaging
3DP process manufactured dosage forms can be packed in either blisters or HDPE bottles. However, packaging printlets presents a challenge especially if they are not mechanically strong. Huge losses may result during packaging. Furthermore, the dosage forms may break during transportation and in-use conditions. Consequently, patients may not receive the correct dose, particularly if they are bulk packed in HDPE bottles. On the other hand, although patients may receive the full dose of printlets packed in blisters provided that broken pieces are consumed too, frag­mented pieces may indicate a quality defect which can not only impact the release and stability characteristics, but also cause patient noncompliance for obvious reasons. Moreover, packing of these tablets requires specialized infrastructure where the dosage form is spread out over the conveyer belt and robotic arms place the individual tablets in the pockets of blisters rather than using conventional blister packing machines (Rahman et al.
2018).
10.5.9 Good Manufacturing Practice Compliant
Current GMP compliance is a must for the manufacturing of drug products intended for human consumption. However, there is a paucity of GMP-compliant 3D printers intended for drug product manufacturing in the commercial space. This is one of the reasons for the lack of wider acceptability of the technique in drug product
manufacturing. The fact that Spritam GMP compliance requirements is an encouraging development (Rahman et al.
2018).
®
manufacturer used their 3D printer to meet
10.6 Regulatory Aspects
The FDA encourages pharmaceutical companies to adopt innovative methods in manufacturing. However, novel manufacturing methods present technical and regulatory challenges to the agency that may cause delays in application submission and eventual approval as the reviewers would require time to familiarize with new technologies and then determine how best to handle it within the existing regulatory framework. The FDA/CDER office of pharmaceutical quality (OPQ) created the Emerging Technology Program (ETP) in 2014 to address these issues. It is a collaborative program where industry representatives can meet with ETT members to discuss, identify, and resolve potential technical and regulatory issues regarding the development and implementation of a technology before filing an application to the FDA for review. It comprises members from OPQ, CDER Office of Compliance, and the Office of Regulatory Affairs. ETT is applicable to IND (Investigational New Drug), original or supplemental BLA (Biologic License Application) or NDA (New Drug Application), ANDA (Abbreviated New Drug Application), and applications