Viral clearance studies …. are they needed for proteins produced using bacterial or yeast fermentation processes?

Dr. Ray Nims

In E. coli or Pichia pastoris-based bioproduction of recombinant proteins, there are no suitable host cells for amplification of viruses that are infectious for humans. Bacteria such as E. coli and yeast such as P. pastoris can only support the growth of certain bacteriophage or yeast viruses, respectively. These types of viruses are not infectious for humans or animals.

The potential for viral infection of a bacterial cell process or a yeast cell process used for production of a recombinant protein is therefore a business risk, not a patient safety risk. This is the reason why case studies of bacteriophage infection of bacterial fermentation processes or of viral contamination of yeast cell processes have not appeared in the literature (or in the news). Unlike virus contamination of animal cell-based production processes, the events involving bacterial or yeast do not have patient safety implications. When a bacteriophage or yeast virus contamination occurs, manufacturers quietly go about the business of restarting the fermentation. Remediation and prevention of future occurrences is driven primarily by business concerns, as opposed to regulatory concerns.

Manufacturers of recombinant proteins produced using bacterial or yeast cell substrates are not required to conduct cell line viral testing (though phage induction studies may be performed as part of bacterial cell line characterization – to mitigate business risk!), nor are they required to conduct lot-by-lot viral testing of bulk harvest samples. Such requirements are mandated for production processes using animal or human cells. As the title of the document “Quality of Biotechnological Products: Viral Safety Evaluation of Biotechnology Products Derived from Cell Lines of Human or Animal Origin” indicates, the ICH Q5A (R1) guidance mandating such testing is clearly directed toward manufacturing processes utilizing the types of cells which may support growth of viruses infectious for human or animal cells. This ICH document also provides guidance on the conduct of viral clearance studies.

Viral clearance studies are intended to provide evidence of the ability of downstream purification steps of a manufacturing process to remove or inactivate viruses that potentially may contaminate the process, make their way into final product, and represent a health risk to patients. As such, the evaluation typically involves both relevant viruses (i.e., viruses that are known to contaminate these kinds of processes) and model viruses (i.e., viruses representative of the types of viruses that could contaminate these processes). In the case of bacteria- and yeast-based manufacturing processes, the relevant viruses (bacteriophage and yeast viruses, respectively) are not infectious for humans or animals. In addition, there are no model viruses that are capable of infecting these kinds of cells that are of concern for humans or animals. Therefore, viral clearance studies are typically not required or conducted.

Are there any circumstances where a bacterial or yeast fermentation process could be expected to harbor a virus capable of infecting humans? The only that I can imagine is a process utilizing primary or secondary animal-derived raw materials in rather large quantities. The worry would not be that viral amplification might occur, but that some carryover of surviving animal viruses to the final product might be possible. The use of such animal-derived materials by a manufacturer of a therapeutic protein must be justified based on risk analysis. If substantial risk is introduced by the use of such raw materials, then perhaps a raw material treatment approach would need to be validated.

In the absence of the use of animal derived materials or plant materials not subject to processing steps that would inactivate contaminating animal viruses, incorporation and validation of viral clearance steps into protein production processes using bacteria or yeast cell substrates is not expected, nor would this be of practical value in assuring patient safety.

Update: New USP General Chapter 1050.1

By Dr. Ray Nims

There is a new general chapter being prepared for inclusion in the United States Pharmacopeia (USP). It will be entitled “Design, Evaluation, and Characterization of Viral Clearance Procedures” and will be numbered 1050.1 to associate it with the current General Chapter <1050>.

A little history is called for to make this association more clear. Chapter <1050> first appeared in supplement 10 of USP23-NF-18 in 1999. It was, and still is, a verbatim copy of the International Conference on Harmonisation (ICH) document Q5A R1. In fact, it has an identical title: “Viral Safety Evaluation of Biotechnology Products Derived from Cell Lines of Human or Animal Origin”.

In many respects, U5P Chapter <1050> (and ICH Q5A R1) is similar in content and philosophy to the 1993 US FDA Points to Consider (PTC) document entitled "Characterization of Cell Lines used to Produce Biologicals".  Like the 1993 PTC, USP Chapter <1050> expresses an overall safety paradigm composed of three orthogonal approaches. These approaches may be summed up as consisting of testing of raw materials and cell banks, testing of unprocessed bulk harvest, and evaluation of viral clearance steps used during purification. Also like the 1993 PTC, Chapter <1050> describes potential sources of viral contamination, including raw materials and the cell substrate. The scopes of the documents are similar, applying to products derived from cell lines. Transmissible spongiform encephalopathy agents and live or inactivated intact viral vaccines and gene therapy vectors are out of scope and are covered by other guidance documents.

Due to the potential for introducing a viral contaminant through use of an infected cell substrate (e.g., SV40 in polio vaccine, or more recently PCV-1 in rotavirus vaccine), USP Chapter <1050> and the 1993 PTC address the concept of cell banking and the extensive viral testing that is required for cell banks at the Master Bank, Working Bank, and Limit of Cell Growth levels. The second approach of the safety paradigm is the requirement for lot-to-lot testing of the unprocessed bulk harvest. Testing is done at this level as opposed to purified product since purification is designed to eliminate viruses and therefore might preclude the manufacturer from discovering a viral infection. It is the intent of the regulatory agencies that potential opportunities for introduction of a viral contaminant be investigated and remediated, so testing is done prior to purification. The viral testing that is required for unprocessed bulk harvest is a subset of the tests done on the cell banks.

Both USP Chapter <1050> and the 1993 PTC discuss the limitations of viral testing as a sole means to assure viral safety, and this provides a segue for discussion of the need for viral clearance steps and the validation of the ability of such steps to clear viruses from the product. In fact, USP Chapter <1050> does a good job of providing the fundamentals of viral clearance evaluation, however there was a feeling expressed by some in the industry (and especially Mike Rubino, a member of the original ad hoc advisory panel for this chapter) that more detailed guidance on experimental design was needed. This, by the way, is true in general about Chapter <1050> (and IQH Q5A Rl upon which USP <1050> was based) that it is strong on philosophy but weak on specific methodological detail.

The original USP ad hoc advisory panel for Chapter <1050> revision was assembled with the purpose of updating the chapter to include this missing experimental detail. The panel went through each section of the existing chapter and added the detail that was felt to be lacking. This was done with the overall mandate to avoid introducing any new language that might conflict with the original language (and ICH Q5A Rl). The revised Chapter <1050> was published in the Pharmacopeial Forum in 2010. Responses obtained indicated that there was reluctance to modify in any way the language of this chapter without also modifying ICH Q5A. The situation as of February 2011 was described in an earlier posting.

As a result, the USP decided to keep Chapter <1050> intact and identical to ICH Q5A Rl.  A new ad hoc advisory panel was assembled with the purpose of producing a new chapter in the general information series that would be a companion to the existing Chapter <1050>. The new chapter received the number 1050.1 and provided the vehicle for adding the desired methodological detail.

The proposed new General Chapter <1050.1>, entitled "Design, Evaluation, and Characterization of Viral Clearance Procedures" consists of some background information on process evaluation and process characterization, then launches into experimental design for evaluating both inactivation and removal steps. The latter section includes some specific experimental design flow charts addressing virus removal by filtration and chromatography and virus inactivation. Along with the flow charts describing the design of the studies are description of the methods used to assess potential cytotoxicity or interference caused by the process materials themselves.

The subheadings of the background information are shown in the text box below.

The information presented under these subheadings reflects the panel's understanding of current regulatory expectations. Regulatory input obtained during the public comment period will assure that the panel's perceptions were correct. Discrepancies will be corrected as required.

Finally, a goal of the new chapter was to provide an updated list of the types of viruses that have been and may be used in viral clearance evaluations. For studies enabling clinical trials, it is common for evaluations to use a parvovirus such as MMV and a retrovirus such as X-MuLV as models. This provides a small non-enveloped virus to challenge filtration steps, as well as an enveloped virus to assess inactivation steps designed for lipid enveloped viruses. For BLA enabling studies, a few additional viruses may be selected from this updated list, keeping in mind that the viruses should represent a diversity of characteristics (envelope status, genome type, size, etc.).

The intention of the new chapter <1050.1> is that manufacturer’s may use the methods as appropriate to their own processes and will be able to cite the guidance in their descriptions of the study design. At the present time, no guidance having sufficient experimental design descriptions is available to cite in this respect. The planned date for publication of the proposed chapter in the Pharmacopeial Forum is January 2013.

What's up with USP Chapter 1050?

by Dr. Ray Nims

United States Pharmacopeia (USP) general chapter <1050> Viral Safety Evaluation of Biotechnology Products Derived from Cell Lines of Human or Animal Origin originally appeared in supplement 10 to USP23-NF18 in May 1999 and was at that time essentially a verbatim adoption of the International Conference of Harmonization (ICH) Guideline Q5A (R1) having the same title.

The chapter describes the methods of evaluating the viral safety of biotechnology pharmaceutical products that are manufactured using cell lines of human or animal origin.

In 2006, an ad hoc advisory panel was assembled by the USP and tasked with revision of this chapter. The goals were to update the chapter and, more specifically, to add greater detail in the viral clearance validation section. The hope was that a user following the recommendations set forth in the general chapter would have greater confidence that viral clearance validation data generated would prove acceptable to the regulatory agencies.

The organization of the revised chapter <1050> was not changed. It comprised the following main sections: 1) Introduction; 2)Potential sources of viral contamination; 3) Cell line qualification: testing for viruses; 4) Testing for viruses in unprocessed bulk; 5) Rationale and action plan for viral clearance studies and viruses tests on purified bulk; and 6) Evaluation and characterization of viral clearance procedures. The changes proposed for the initial 5 sections were minor and primarily reflected attempts to update the chapter and to align the chapter more closely with FDA guidance documents. The most extensive changes were to section 6, in keeping with the goals described above.

The revised chapter was published for public comment in Pharmacopeial Forum 36(3) in the fall of 2010. Comments received as a result of the public review apparently suggested that a more extensive update of the chapter was warranted. At any rate, the revised chapter was not made effective during the USP’s 2005-2010 revision cycle. A new ad hoc advisory panel now being assembled as part of USP's 2010-2015 revision cycle will take over the responsibility for moving the revision of this chapter forward.

Is Clarence calculating clearance correctly?

by Dr. Ray Nims

As pointed out by Dr. Rudge in a recent posting “Do we have clearance, Clarence?”, spiking studies conducted for the purpose of validating impurity clearance are often done at only one spiking level (indeed often at the highest possible impurity load attainable). This is especially true for validation of adventitious agent (virus and mycoplasma) clearance in downstream processes. The studies are done in this way in order to determine the upper limit of agent clearance (in terms of log10 reduction) by the process. Such log10 reduction factors from individual process steps are then summed in order to determine the overall capability of the downstream processes to clear adventitious agents. The regulatory agencies have fairly clear expectations around such clearance capabilities which must generally be met by biologics manufacturers.

The limiting factor in such clearance studies is typically the amount or titer of the agent that is able to be spiked into the process solution, which is determined by: 1) the titer of the stock used for spiking, and 2) the maximum dilution of the process solution allowed during spiking (typically 10%). Under these circumstances, as Scott points out, there is a possibility that the determined clearance efficiency (i.e., the percentage of the load which is cleared during the step) is an underestimate of the actual clearance that might be obtained at lower impurity loading levels.

Adventitious agent clearance is comprised of two possible modalities, removal and inactivation. Removal refers to physical processes designed to eliminate the agent from the process solution, usually through filtration or chromatography. Removal efficiency through filtration would not be expected to display variability based on impurity loading. On the other hand, chromatographic separation of agents (by, for example, ion-exchange columns) may display saturation at the highest loadings, and therefore use of the highest possible loading levels may result in underestimates of removal efficiency at lower (i.e., more typical) impurity levels.

Inactivation refers to physical or chemical means of rendering the agent non-infectious. Agent inactivation is not always a simple, first-order reaction. It may be more complex, with a fast phase 1 stage of inactivation followed by a slow phase 2 stage of inactivation. An inactivation study is planned in such a way that samples are taken at different times so that an inactivation time curve can be constructed. As with removal studies, the highest possible impurity levels are typically used to determine inactivation kinetics.

Source: Omar et al. Transfusion 36:866-872, 1996

While the information obtained through clearance studies of this type may be incomplete from the point of view of understanding the relationships between impurity loading levels and clearance efficiency, the results obtained are consistent with the regulatory expectation that the clearance modalities be evaluated under worst-case conditions. Therefore, at least in the case of adventitious agent clearance validation, I would say that Clarence is calculating clearance correctly!

Do We Have Clearance, Clarence?

By Dr. Scott Rudge

As in take offs and landings in civil aviation, the ability of a pharmaceutical manufacturing process to give clearance of impurities is vital to customer safety. It’s also important that clearance mechanism be clear, and not confused, as the conversation in the classic movie “Airplane!” surely was (and don’t call me Shirley).

There are two ways to demonstrate clearance of impurities.

The first is to track the actual impurity loads. That is, if an impurity comes into a purification step at 10%, and is reduced through that step to 1%, then the clearance would typically be called 1 log, or 10 fold.

The second is to spike impurities. This is typically done when an impurity is not detectable in the feed to the purification step, or when, even though detectable, it is thought desirable to demonstrate that even more of the impurity could be eliminated if need be.

The first method is very usable, but suffers from uneven loads. That is, batch to batch, the quantity and concentration of an impurity can vary considerably. And the capacity of most purification steps to remove impurities is based on quantity and concentration. Results from batch to batch can vary correspondingly. Typically, these results are averaged, but it would be better to plot them in a thermodynamic sense, with unit operation impurity load on the x-axis and efflux on the y-axis. The next figures give three of many possible outcomes of such a graph.

In the first case, there is proportionality between the load and the efflux. This would be the case if the capacity of the purification step was linearly related to the load. This is typically the case for absorbents, and adsorbents at low levels of impurity. In this case (and only this case, actually) does calculating log clearance apply across the range of possible loads. The example figure shows a constant clearance of 4.5 logs.

In the second case, the impurity saturates the purification medium. In this case, a maximum amount of impurity can be cleared, and no more. The closer to loading at just this capacity, the better the log removal looks. This would be the point where no impurity is found in the purification step effluent. All concentrations higher than this show increasing inefficiency in clearance.

In the third case, the impurity has a thermodynamic or kinetic limit in the step effluent. For example, it may have some limited solubility, and reaches that solubility in nearly all cases. The more impurity that is loaded, the more proportionally is cleared. There is always a constant amount of impurity recovered.

For these reasons, simply measuring the ratio of impurity in the load and effluent to a purification step is inadequate. This reasoning applies even more so to spiking studies, where the concentration of the impurity is made artificially high. In these cases, it is even more important to vary the concentration or mass of the impurity in the load, and to determine what the mechanism of clearance is (proportional, saturation or solubility).

Understanding the mechanism of clearance would be beneficial, in that it would allow the practitioner to make more accurate predictions of the effect of an unusual load of impurity. For example, in the unlikely event that a virus contaminates an upstream step in the manufacture of a biopharmaceutical, but the titer is lower than spiking studies had anticipated, if the virus is cleared by binding to a resin, and is below the saturation limit, it’s possible to make the argument that the clearance is much larger, perhaps complete. On the other hand, claims of log removal in a solubility limit situation can be misleading. The deck can be stacked by spiking extraordinary amounts of impurity. The reality may be that the impurity is always present at a level where it is fully soluble in the effluent, and is never actually cleared from the process.

Clearance studies are good and valuable, and help us to protect our customers, but as long as they are done as single points on the load/concentration curve, their results may be misleading. When the question comes, “Do we have clearance, Clarence?” we want to be ready to answer the call with clear and accurate information. Surely varying the concentration of the impurity to understand the nature of the clearance is a proper step beyond the single point testing that is common today.

And stop calling me Shirley.