Approaches to Design an Efficient, Predictable Global Post-approval Change Management System that Facilitates Continual Improvement and Drug Product Availability

The complexity and inter-connectedness of operating in a global world for drug product supply has become an undeniable reality, further underscored by the COVID-19 pandemic. For Post-Approval Changes (PACs) that are an inevitable part of a product's commercial life, the impact of the growing global regulatory complexity and related drug shortages has brought the Global PAC Management System to an inflection point in particular for companies that have their products marketed in many countries.This paper illustrates through data analyzed for the first time from 145,000 + PACs for 156 countries, collected by 18 global pharma companies over a 3-year period (2019-2021), how severe the problem of global regulatory complexity is. Only PACs requiring national regulatory agency (NRA) approval prior to implementation were included in the data set. 1 of the 156 country NRAs approved all submitted PACs within a period of 6 months. The 6-month timeline was chosen because it is the recommended review timeline for major changes in the WHO guidance for vaccines and biotherapeutic products. 10 out of the 156 (6%) countries had no more than 10% of the PACs reviewed and approved in > 6 months. In 33 (22%) countries more than half of the PACs took > 6 months for approval. It is rare that the same PAC is approved globally within 6 months as individual NRAs take from a few months to years (in some cases > 5 years) for their review.The global PAC management complexity has steadily grown over the past 20 years. Attempts thus far to solve this problem have not made any meaningful difference. Senior leaders and decision-makers across the interdependent components of the complex Global PAC Management System (industry and regulators) must come together and collaboratively manage the problem holistically with the objective of ensuring global drug product availability instead of continuing with distinct stakeholder or country-focused solutions, which can tend to worsen the problem.In this paper, the Chief Quality Officers (CQOs) from 18 of the largest innovator pharma companies (see Acknowledgements) are speaking with One-Voice-of-Quality for PACs (1VQ for PACs Initiative). They are recommending a set of 8 approaches to activate a holistic transformation of the Global PAC Management System. This article presents their view on the problem of global regulatory complexity for managing PACs, it's impact on continual improvement and the risk to drug product supply, as well as approaches that can help alleviate the problem.

In-Situ Phase Separation of an Amine-Terminated Siloxane in Epoxy Matrices

We have developed an amino-functional silicone resin to toughen epoxies which, when prereacted with the epoxy function in resins, undergoes in-situ phase separation during final epoxy curing. SEM analyses of the morphology of fracture surfaces of MY720- DDS, Epon 828-DDS and other epoxy matrices modified with the silicone resin showed rough surfaces with the formation of very uniform <10 μm spheres. Silicon and sulfur elemental distribution mapping showed silicon rich spheres embedded in an epoxy matrix. We report cavitation, particle debonding and pull-out, and an increases in fracture surface area as possible modes of toughening. Silicone modified materials give improvements in slow strain rate G1c fracture toughness measurements of 250–400%, similar to carboxy terminated polybutadiene-acrylonitrile copolymer (CTBN) modifiers, but with a much smaller flexural modulus loss. The Tg of the modified epoxy matrices are maintained, moisture resistance is improved, and flammability is reduced.