Title: IBC Final 43004
1Recombinant Anti-Hemophilic Factor - A Case Study
in Post Licensure Evolution of Specifications
- Mehrshid Alai, Ph.D
- Baxter Healthcare Corporation
- October 2004
2Factor VIII Structure
Synthesized as a polypetide chain of 2,332 amino
acids which is cleaved into a dimer as it is
produced in cells.
3Factor VIII Structure and Function
Adapted from Lenting PJ et al. Blood 1998
923983-96
4Factor VIII Biological Activity
5Hemophilia A
- Hemophilia A is an X-linked bleeding disorder
associated with a deficiency of functional factor
VIII. - Over 200 different mutations known.
- Clinical Severity
- Mild 5 factor level Bleeding only
withsignificant trauma or surgery only
occasionalhemarthroses, with trauma - Moderate 15 factor level Bleeding with mild
trauma hemarthroses with trauma occasionally
spontaneous hemarthroses - Severe hemarthroses and soft tissue bleeding
6Hemophilia Therapy
- Replacement therapy with factor VIII corrects the
clotting deficiency. - Typical dosage is 30-50 IU/Kg
- 1 µg factor VIII 5 IU
- Therapeutic dose 6-10 µg/Kg
- Prior to the advent of the technology for the
commercial production of recombinant proteins
factor VIII concentrates were plasma (human or
porcine) derived.
7Factor VIII Immunogenicity
- The incidence of inhibitor formation is related
to the severity of the disease and the nature of
the mutation. - 25 for severe hemophiliacs
- 5 to 15 for mild to moderate hemophiliacs
- Higher in patients whose mutation interferes with
factor VIII biosynthesis - Inhibitor development is the most significant
adverse event associated with factor VIII
therapy. Alterations in factor VIII
manufacturing process have been associated with
increases in immunogenicity.
8Factor VIII Inhibitors
- A2 and C2 domains are antigenic hotspots
- A significant portion of factor VIII inhibitors
are
proteolytic antibodies - Inhibitory anti-C2 antibodies also block vWF and
membrane binding - Lacroix-Desmazes
S et al. NEJM 2002 346 662-667
9RECOMBINATE rAHF Manufacturing Process
Fed Batch Bioreactor
Harvest / Clarification
Process Notes CHO Host Cell Continuous Culture -
24/7 Immunoaffinity Mass Capture
Affinity and Ion Exchange Purification
Bulk
Formulation and Lyophilization
10RECOMBINATE rAHF Cell Culture Production Process
11RECOMBINATE rAHF Purification and Finishing
Processes
12RECOMBINATE Specifications
13RECOMBINATE rAHF Licensure
- Approved in 1992 as the first recombinant factor
VIII product. - 1993 Licensure in Europe and other geographies.
- Specifications for bulk drug substance and final
product aggregate of all geographic requirements.
14History of Licensure
- It is one of the first complex recombinant
products being licensed. - It is manufactured in two facilities, by two
entities. - Extensive release testing is part of ensuring
product quality. -
- Due to higher product concentration and purity,
the product is extensively tested and
characterized at the BDS stage.
15Characterization vs. Release Testing
- Tests such as amino acid (a.a.) sequence analysis
are typically considered as characterization
tests and unless there is a reason to suspect
changes in the a.a. sequence, it is not necessary
to test the a.a. for release of every lot. - A photospectrum analysis should be done as a
characterization tool to define appropriate
wavelength to measure protein concentration and
for routine release of product.
16Process Related Impurities
- Many upstream process related impurities are
removed in the downstream purification process.
During process validation data can be generated
to assure removal of such impurities. - Even though, Baxter had generated data on removal
of process related impurities, due to lack of
history with recombinant products release testing
of impurities was suggested/required.
17Two Specific Examples
- Residual Host Cell DNA
- Residual Host Cell Protein (HCP)
18Residual Host Cell DNA
- At the time of development and registration of
RECOMBINATE, residual Host cell DNA was
considered to be a potential safety risk to the
patients. - In 1987, a World Health Organization consultative
group recommended that the safety risk was
negligible in products containing less than 100
pg/dose of cellular DNA.
19Residual Host Cell DNA
- In an FDA/CBER-sponsored workshop on Well
Characterized Biotechnology Products held in
December 1995, it was concluded that process
validation could provide a more appropriate and
effective means of demonstrating product
consistency and purity. - At this meeting it was proposed and is generally
accepted that appropriate validation of DNA
removal could obviate the need for routine DNA
testing.
20Residual Host Cell DNA
- As part of routine release testing for further
manufacturing use, each batch of rAHF concentrate
was assayed for residual host cell DNA. - The specification for this test was set at a
maximum of 10 pg/1000 unit dose.
21Experience with Host Cell DNA
- After years of experience with recombinant
products, residual host cell DNA is not
considered a major safety concern.
22Rationale for Elimination of Residual DNA Testing
- Baxter submitted a pre-approval supplement
requesting elimination of routine lot-to-lot
testing for residual host cell DNA based on - concurrent evaluation of DNA in samples of
in-process pools from full scale manufacturing
batches - prospective-scale challenge studies using
radioactive labeled DNA spiked into the process
intermediates - experience with 1000 batches of rAHF concentrate
consistently meeting specifications which was
significantly below the safety threshold set for
host cell DNA.
23Rationale for Elimination of Residual DNA Testing
- The results of the studies showed that
- the DNA challenge to the purification process is
predictable and consistent in terms of size and
the amount of DNA - the purification process is robust and has
capacity to remove DNA to levels below the
specification - the purification process can reproducibly remove
DNA to acceptably low levels.
24The Outcome
- The supplement was approved by the agency with
the commitment of using the residual DNA testing
for monitoring process changes.
25Residual Host Cell Protein
- As part of routine testing, for further
manufacturing, each batch of rAHF Concentrate is
tested for residual host cell protein levels,
using the Chinese Hamster Ovary (CHO), by
immunoligand assay (ILA). - The licensed specification was less than or equal
to 1.0 ug/1000 IU rAHF. - Baxter prepared a pre-approval supplement to
increase the residual level to 1.5 ug/1000 IU
rAHF.
26Rationale for Changing the Specifications
- Original specification was based on limited data,
consisting of 13 batches. - After extensive experience with the process,
1000 batches, specification was found to be to
close to the capability of the process. - Retrospective evaluation of in-process parameters
including chromatographic separation of CHO
proteins and rAHF was made. - 99.9 of total CHO proteins are removed in the
first step of the purification process.
27Rationale for Changing the Specifications (contd)
- The analysis of CHO proteins showed that the
differences between the batches below the
specification and above the specifications were
only quantitative and not qualitative. - All other physcio-chemical parameters showed
process consistency. - Calculation of the specification involves two
biological assays which bring variability to the
results.
28Clinical Data in Support of Change of HCP
Specification
- Based on two prospective clinical trials and
post-licensure pharmacovigliance activities, it
was concluded that RECOMBINATE has a high level
of tolerability and safety when administered at a
very high dose (as for immune tolerance) over
long time intervals.
29Clinical Data in Support of Change of HCP
Specification
- There is no relationship between residual CHO
protein and the clinical adverse experience. - Baxter made a commitment to conduct a prospective
study with moderately increased levels of CHO
protein levels (i.e. 1.2 and 1.5 ug/1000 IU).
30Change in the HCP Specifications
- The proposed change of CHO specifications was
approved by FDA on October 22, 1998 and by EU
countries on August 30, 1999. - Baxter has successfully conducted the prospective
Pharmaco-surveillance Study of Anti-Hemophilic
Factor, RecombinateTM, Manufactured with Modestly
Increased CHO cell Protein Levels.