Pharmaceutical Technology Europe-09-01-2003

Improving product quality and lowering costs are the key factors behind the decisions made in many industries. Ensuring product quality throughout the manufacturing process can be time-consuming, with materials and products 'quarantined' until test results are generated. Rapid testing by near-infrared (NIR) spectroscopy at all stages of the manufacturing process can reduce production time and provide assurances at each step of the process that product quality is being maintained.

More than 6 years have elapsed since the US Food and Drug Administration's (FDA's) 21 CFR Part 11 regulations regarding the use of electronic records and electronic signatures came into effect.1 In February 2003, FDA issued new draft guidance concerning the scope and application of Part 11, which describes how the agency intends to interpret and enforce the requirements during its ongoing re-examination of the regulations.2 Many people in the pharmaceutical industry have welcomed this new guidance and see it as a positive development that will lead to a simplified FDA approach to Part 11 and a significant reduction in the industry's compliance burden.

Paper batch records have been used for decades to record procedures, the type and quantity of each material used, and the status of each step in the manufacturing process for both pharmaceuticals and medical devices. Although paper batch records are less complicated to implement than their electronic counterparts, and the controls required for data recording and archival are well understood, a paper batch record system is laborious to maintain and prone to human error, which increases the compliance risk. Additionally, batch records have become bulky and more time consuming to prepare and review, particularly as manufacturing operations become increasingly complicated. Advances in technology and science have created a more competitive climate in life science industries than ever before, causing the need for manufacturers to reduce costs and time-to-market, and improve their ability to satisfy the compliance requirements of US Food and Drug Administration (FDA) regulations. The use of electronic batch recording systems (EBRS) and electronic batch records (EBR) offers one solution.

Respirable drug delivery is becoming increasingly popular because it provides a non-invasive route with rapid drug uptake, not only for the treatment of respiratory complaints, but also for the systemic delivery of substances that cannot be delivered orally.

There can be little argument that packaging is at the forefront of the fight against counterfeit drugs, which currently costs the industry between 6-10% of the value of pharmaceutical sales. According to IMS Health, the figure is approximately $22 billion from global pharmaceutical sales of $364 billion. To set this in context, counterfeiting of all goods costs $200-400 billion annually, claims the Global Anti-Counterfeiting Group. According to the the US Pharmaceutical Manufacturers Association, it can take an average of $250 million and 10 years to legally develop and market a drug, but it is possible for a counterfeiter to 'reproduce' a product within a couple of months for as little as $250000.

The goal of an enterprise public-key infrastructure (PKI) is to protect information assets through electronic-based solutions that comprise hash algorithms, data encryption, digital certificates, message digests, digital signatures and audit logs. The key condition and solution critical to 21 CFR Part 11 are authentication and encryption, respectively. Authentication verifies a person's identity as well as the integrity of records. Encryption protects the privacy of records. Although most information transactions do not require this level of comprehensive digital trust, PKI is the best choice for ensuring compliance with Part 11 security requirements and consequently for ensuring the privacy of records.

Part I of this article was published in the March 2003 issue of 21 CFR Part 11: Compliance and Beyond. In this issue, Part II discusses the potential advances and changes that must be made for computer validation to remain innovative and relevant to the industry.

In an interview earlier this year (Bio-IT World, April 2003), Janet Woodcock, director of the Center for Drug Evaluation and Research (CDER), stated that "The original intent of the rule (21 CFR Part 11) was to facilitate the introduction of electronic technology to the process of the US Food and Drug Administration (FDA) submissions, as well as manufacturing and production. Part 11 was created to provide common-sense guidelines on how to do in the electronic world what was previously done on paper. During the last 5 years, however, confusion regarding what is included in the regulation and how to enforce it was impeding the introduction of new technology. The rule had created exactly the opposite of what was intended."