By Dr. Ray Nims
In a previous posting, we described the responsibilities of the contract giver (contractee) and the contract acceptor (contractor) in outsourced pharmaceutical quality control testing. Our blog title: "Outsource it, and fuggedaboutit?" somewhat facetiously suggested that the outsourcing of quality control testing does not transfer quality control responsibility from the contract giver to the contract acceptor.
Elizabeth Meyers and I expanded upon this theme in a recent article in BioProcess International. Our conclusion in that article was more direct: “The use, by a pharma organization, of a contract testing lab to fulfill some or all of its Quality Control testing obligations does not absolve the contractee of its overall Quality responsibility of ensuring the safety, purity, identity, efficacy, and potency of its products.”
This point was illustrated nicely in a recent warning letter published on the FDA Website. The name of the firm involved is not important to this discussion. Among the other findings was the following:
“Your firm failed to properly evaluate a contract laboratory to ensure GMP compliance of operations occurring at the contract site.”
The FDA then provided the following detail: "...we are concerned about your firm’s fundamental understanding of what is required by your Quality Unit and the regulatory expectations for a firm that enters into agreements with contract testing laboratories. Although you have agreements with other firms that may delineate specific responsibilities to each party, you are ultimately responsible for the quality of your products and the reliability of test results. Regardless of who tests your products or the agreements in place, you are required to manufacture these products in accordance with section 501(a)(2)(B) of the Act to assure their identity, strength, quality, purity, and safety."
The take-home message from this is that in the outsourcing of quality control testing, responsibility for the outsourced testing is retained by the contract giver. Responsibilities of the contract giver include the following: selecting and qualifying the contract lab, ensuring the suitability of methods used (through qualification, transfer, verification, or validation); putting in place a Quality and business agreement; scheduling and submitting samples (including communicating expectations for sample results); providing in-life guidance; and monitoring of contract lab performance.
There is no denying that fulfilling these responsibilities requires a significant and ongoing effort on the part of the contract giver. In this respect, outsourcing of quality control testing is not so different from doing that testing in-house.
Friday, February 25, 2011
Wednesday, February 16, 2011
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.
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.
Friday, January 21, 2011
Remember....bacteriophage are viruses too
by Dr. Ray Nims
Are you using bacterial cells to produce a biologic? Do not make the mistake of thinking that your upstream process is safe from infection by adventitious viruses. True, you are not required to test for the usual viruses of concern using a lot release adventitious virus assay. But bacterial production systems are susceptible to introduction of viruses just as mammalian cell processes are. In this case, the viruses just happen to be referred to as bacteriophage. Other than this, the putative contaminants have the same nasty property exhibited by viruses that can contaminate mammalian cell processes, that is … their small size (24-200 nm) allows them to readily pass through the filters used to “sterilize” process solutions. So media, buffers, induction agents, vitamin mixes, trace metal mixes, etc. that are fed into the fermenter without proper treatment can introduce a bacteriophage. Especially worrisome in this regard are raw materials that are generated through bacterial fermentation (such as amino acids, antibiotics). A fermenter infected with a lytic phage exhibits a clear signal that the bacterial substrate is unhappy. The trick then is to discover where the phage originated and to mitigate the risk of experiencing it again.
How can you mitigate the risk of experiencing a bacteriophage infection? Many of the same strategies used to protect mammalian cell processes may be applicable to the bacterial fermentation world. Raw materials and/or process solutions may be subjected to gamma-irradiation, to ultraviolet light in the C range, to prolonged heating or to high temperature short time treatment, to viral filtration, etc. In addition, mitigation of risk of bacteriophage contamination may require filtration of incoming gasses using appropriate filters.
A sampling of the data available on inactivation of bacteriophage by various methods is shown in the table below. The literature is extensive, and as with viral inactivation, the inactivation of phage by certain of the methods (e.g., UVC, gamma-irradiation) may be dependent both upon the matrix in which the phage is suspended as well as the physical properties of the phage (e.g., genome or particle size, strandness, etc.). For fairly dilute aqueous solutions, gamma-irradiation, UVC treatment, or parvovirus filtration should represent effective inactivation/removal methods. HTST at temperatures effective for parvoviruses (102°C, 10 seconds) should be effective for most bacteriophage, although this is an area that needs further exploration.
Mitigating the risk of experiencing a bacteriophage contamination of a bacterial fermentation process is possible if one remembers that bacteriophage are similar to mammalian viruses. Strategies that are effective for small-non-enveloped mammalian viruses (i.e., the worst case for mammalian viruses) should also be effective for most bacteriophage.
A possible exception to this is prophage. In analogy with the presence of endogenous retroviruses in certain mammalian cells (i.e., rodent, human, monkey), there is a possibility of encountering integrated bacteriophage (prophage) in certain bacterial cell lines. Like endogenous retroviruses, prophage may result in the production of infectious particles under certain conditions. This phenomenon deserves some discussion, but this will have to be deferred to a future blog.
References: Purtel et al., 2006; Ward, 1979; Sommer et al., 2001.
Are you using bacterial cells to produce a biologic? Do not make the mistake of thinking that your upstream process is safe from infection by adventitious viruses. True, you are not required to test for the usual viruses of concern using a lot release adventitious virus assay. But bacterial production systems are susceptible to introduction of viruses just as mammalian cell processes are. In this case, the viruses just happen to be referred to as bacteriophage. Other than this, the putative contaminants have the same nasty property exhibited by viruses that can contaminate mammalian cell processes, that is … their small size (24-200 nm) allows them to readily pass through the filters used to “sterilize” process solutions. So media, buffers, induction agents, vitamin mixes, trace metal mixes, etc. that are fed into the fermenter without proper treatment can introduce a bacteriophage. Especially worrisome in this regard are raw materials that are generated through bacterial fermentation (such as amino acids, antibiotics). A fermenter infected with a lytic phage exhibits a clear signal that the bacterial substrate is unhappy. The trick then is to discover where the phage originated and to mitigate the risk of experiencing it again.
How can you mitigate the risk of experiencing a bacteriophage infection? Many of the same strategies used to protect mammalian cell processes may be applicable to the bacterial fermentation world. Raw materials and/or process solutions may be subjected to gamma-irradiation, to ultraviolet light in the C range, to prolonged heating or to high temperature short time treatment, to viral filtration, etc. In addition, mitigation of risk of bacteriophage contamination may require filtration of incoming gasses using appropriate filters.
A sampling of the data available on inactivation of bacteriophage by various methods is shown in the table below. The literature is extensive, and as with viral inactivation, the inactivation of phage by certain of the methods (e.g., UVC, gamma-irradiation) may be dependent both upon the matrix in which the phage is suspended as well as the physical properties of the phage (e.g., genome or particle size, strandness, etc.). For fairly dilute aqueous solutions, gamma-irradiation, UVC treatment, or parvovirus filtration should represent effective inactivation/removal methods. HTST at temperatures effective for parvoviruses (102°C, 10 seconds) should be effective for most bacteriophage, although this is an area that needs further exploration.
Mitigating the risk of experiencing a bacteriophage contamination of a bacterial fermentation process is possible if one remembers that bacteriophage are similar to mammalian viruses. Strategies that are effective for small-non-enveloped mammalian viruses (i.e., the worst case for mammalian viruses) should also be effective for most bacteriophage.
A possible exception to this is prophage. In analogy with the presence of endogenous retroviruses in certain mammalian cells (i.e., rodent, human, monkey), there is a possibility of encountering integrated bacteriophage (prophage) in certain bacterial cell lines. Like endogenous retroviruses, prophage may result in the production of infectious particles under certain conditions. This phenomenon deserves some discussion, but this will have to be deferred to a future blog.
References: Purtel et al., 2006; Ward, 1979; Sommer et al., 2001.
Tuesday, November 16, 2010
Cell Culturists….Are your human cells authenticated?
by Dr. Ray Nims
Until fairly recently, it has been common practice to authenticate human cell cultures using phenotypic status (e.g., receptor or protein expression) and animal species of origin testing. This level of authentication is better than none, but it is not sufficient to unambiguously identify a human cell culture. The result has been that we are still hearing about cases of misidentified human cells being used for biomedical research.
There are now methods available that are capable of rapidly and unambiguously identifying human cell lines, tissues, and cell preparations to the individual level. The recent demonstration of the potential utility of molecular technologies such as short tandem repeat (STR) and single nucleotide polymorphism (SNP) profiling for cell authentication has provided the impetus for development of a new standardized method for human cell authentication.
To this end, an ATCC Standards Development Organization workgroup with international representation has spent the past two years developing a consensus standard for the Authentication of Human Cell Lines through STR Profiling. The forthcoming Standard will provide guidance on the use of STR profiling for authenticating human cells, tissue, and cell lines. It will contain methodological detail on the preparation and extraction of the DNA, guidance on the appropriate numbers and types of loci to be evaluated and on interpretation and quality control of the results. Associated with the standard itself will be the establishment of a public STR profile database which will be administered and maintained by the National Center for Biotechnology Information (NCBI). The database primarily will contain STR profiles of commonly used cell lines.
STR Profiling of Hela Cells
An announcement that the Standard is now available for public 45-day review, comment, and vote was published in the October 22, 2010 issue of the ANSI newsletter Standards Action.
The benefits of the Standard will depend on the degree to which it is adopted and followed in the biomedical research and development and biopharmaceutical communities. Taking a broader view, it is hoped that funding agencies and journals will begin to use such authentication standards as important considerations for funding or publishing research employing human cells. The quality and validity of funded and published research should benefit greatly as a result of the reduction in frequency of use of misidentified human cells.
The deadline for comments is December 6, 2010. There is still time to review the draft Standard and to voice your opinions and concerns.
Until fairly recently, it has been common practice to authenticate human cell cultures using phenotypic status (e.g., receptor or protein expression) and animal species of origin testing. This level of authentication is better than none, but it is not sufficient to unambiguously identify a human cell culture. The result has been that we are still hearing about cases of misidentified human cells being used for biomedical research.
There are now methods available that are capable of rapidly and unambiguously identifying human cell lines, tissues, and cell preparations to the individual level. The recent demonstration of the potential utility of molecular technologies such as short tandem repeat (STR) and single nucleotide polymorphism (SNP) profiling for cell authentication has provided the impetus for development of a new standardized method for human cell authentication.
To this end, an ATCC Standards Development Organization workgroup with international representation has spent the past two years developing a consensus standard for the Authentication of Human Cell Lines through STR Profiling. The forthcoming Standard will provide guidance on the use of STR profiling for authenticating human cells, tissue, and cell lines. It will contain methodological detail on the preparation and extraction of the DNA, guidance on the appropriate numbers and types of loci to be evaluated and on interpretation and quality control of the results. Associated with the standard itself will be the establishment of a public STR profile database which will be administered and maintained by the National Center for Biotechnology Information (NCBI). The database primarily will contain STR profiles of commonly used cell lines.
An announcement that the Standard is now available for public 45-day review, comment, and vote was published in the October 22, 2010 issue of the ANSI newsletter Standards Action.
The benefits of the Standard will depend on the degree to which it is adopted and followed in the biomedical research and development and biopharmaceutical communities. Taking a broader view, it is hoped that funding agencies and journals will begin to use such authentication standards as important considerations for funding or publishing research employing human cells. The quality and validity of funded and published research should benefit greatly as a result of the reduction in frequency of use of misidentified human cells.
The deadline for comments is December 6, 2010. There is still time to review the draft Standard and to voice your opinions and concerns.
Wednesday, November 3, 2010
Fry those mollicutes!
By Dr. Ray Nims
It is not only viruses that may be introduced into biologics manufactured in mammalian cells using bovine sera in upstream cell growth processes. The other real concern is the introduction of mollicutes (mycoplasmas and acholeplasmas). Mollicutes, like viruses, are able to pass through the filters (including 0.2 micron pore size) used to sterilize process solutions. Because of this, filter sterilization will not assure mitigation of the risk of introducing a mollicute through use of contaminated bovine or other animal sera in upstream manufacturing processes.
Does mycoplasma contamination of biologics occur as a result of use of contaminated sera? The answer is yes. Most episodes are not reported to the public domain, but occasionally we hear of such occurrences. Dehghani and coworkers reported the occurrence of a contamination with M. mycoides mycoides bovine group 7 that was proven to have originated in the specific bovine serum used in the upstream process (Case studies of mycoplasma contamination in CHO cell cultures. Proceedings from the PDA Workshop on Mycoplasma Contamination by Plant Peptones. Pharmaceutical Drug Association, Bethesda, MD. 2007, pp. 53-59). Contamination with M. arginini and Acholeplasma laidlawii attributed to use of specific contaminated lots of bovine serum have also occurred.
Fortunately, the risk of introducing an adventitious mollicute into a biologics manufacturing process utilizing a mammalian cell substrate may be mitigated by gamma-irradiating the animal serum prior to use. This may be done in the original containers while the serum is frozen. Unlike the case for viruses, in which the efficacy of irradiation for inactivation may depend upon the size of the virus, mollicute inactivation by gamma irradatiion has been found to be highly effective (essentially complete), regardless of the species of molicute. The radiation doses required for inactivation are relatively low compared to those required for viruses (e.g., 10 kGy or less, compared to 25-45 kGy for viruses). The gamma irradiation that is performed by serum vendors is typically in the range of 25-40 kGy. This level of radiation is more than adequate to assure complete inactivation of any mollicutes that may be present in the serum. For instance, irradiation of calf serum at 26-34 kGy resulted in ≥6 log10 inactivation of M. orale, M. pneumoniae, and M. hyorhinis. In the table below I have assembled the data available on inactivation of mollicutes in frozen serum by gamma-irradiation.
So, the good news is that gamma irradiation of animal serum that is performed to mitigate the risk of introducing a viral contaminant will also mitigate the risk of introducing a mollicute contaminant. If the upstream manufacturing process cannot be engineered to avoid use of animal serum, the next best option is to validate the use of gamma irradiated serum in the process. In fact, the EMEA Note for guidance on the use of bovine serum in the manufacture of human biological medicinal products strongly recommends the inactivation of serum using a validated and efficacious treatment, and states that the use of non-inactivated serum must be justified.
References: Gauvin and Nims, 2010; Wyatt et al. BioPharm 1993;6(4):34-40; Purtle et al., 2006
It is not only viruses that may be introduced into biologics manufactured in mammalian cells using bovine sera in upstream cell growth processes. The other real concern is the introduction of mollicutes (mycoplasmas and acholeplasmas). Mollicutes, like viruses, are able to pass through the filters (including 0.2 micron pore size) used to sterilize process solutions. Because of this, filter sterilization will not assure mitigation of the risk of introducing a mollicute through use of contaminated bovine or other animal sera in upstream manufacturing processes.
Does mycoplasma contamination of biologics occur as a result of use of contaminated sera? The answer is yes. Most episodes are not reported to the public domain, but occasionally we hear of such occurrences. Dehghani and coworkers reported the occurrence of a contamination with M. mycoides mycoides bovine group 7 that was proven to have originated in the specific bovine serum used in the upstream process (Case studies of mycoplasma contamination in CHO cell cultures. Proceedings from the PDA Workshop on Mycoplasma Contamination by Plant Peptones. Pharmaceutical Drug Association, Bethesda, MD. 2007, pp. 53-59). Contamination with M. arginini and Acholeplasma laidlawii attributed to use of specific contaminated lots of bovine serum have also occurred.
Fortunately, the risk of introducing an adventitious mollicute into a biologics manufacturing process utilizing a mammalian cell substrate may be mitigated by gamma-irradiating the animal serum prior to use. This may be done in the original containers while the serum is frozen. Unlike the case for viruses, in which the efficacy of irradiation for inactivation may depend upon the size of the virus, mollicute inactivation by gamma irradatiion has been found to be highly effective (essentially complete), regardless of the species of molicute. The radiation doses required for inactivation are relatively low compared to those required for viruses (e.g., 10 kGy or less, compared to 25-45 kGy for viruses). The gamma irradiation that is performed by serum vendors is typically in the range of 25-40 kGy. This level of radiation is more than adequate to assure complete inactivation of any mollicutes that may be present in the serum. For instance, irradiation of calf serum at 26-34 kGy resulted in ≥6 log10 inactivation of M. orale, M. pneumoniae, and M. hyorhinis. In the table below I have assembled the data available on inactivation of mollicutes in frozen serum by gamma-irradiation.
So, the good news is that gamma irradiation of animal serum that is performed to mitigate the risk of introducing a viral contaminant will also mitigate the risk of introducing a mollicute contaminant. If the upstream manufacturing process cannot be engineered to avoid use of animal serum, the next best option is to validate the use of gamma irradiated serum in the process. In fact, the EMEA Note for guidance on the use of bovine serum in the manufacture of human biological medicinal products strongly recommends the inactivation of serum using a validated and efficacious treatment, and states that the use of non-inactivated serum must be justified.
References: Gauvin and Nims, 2010; Wyatt et al. BioPharm 1993;6(4):34-40; Purtle et al., 2006
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