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BIOTECHNOLOGY INSPECTION GUIDE REFERENCE MATERIALS AND TRAINING AIDS

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November 1991

Division of Field Investigations (HFC-130)
Office of Regional Operations
Office of Regulatory Affairs

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
PUBLIC HEALTH SERVICE
FOOD AND DRUG ADMINISTRATION

Note: This document is reference material for investigators and other FDA personnel. The document does not bind FDA, and does no confer any rights, privileges, benefits, or immunities for or on any person(s).

ACKNOWLEDGEMENTS

This Guide was initiated by Robert C. Fish, Director, Division of Field Investigations (DFI). Mr. Fish asked Barbara-Helene mith, Ph.D., DIB, CHI-DO, to chair a workgroup to develop inspectional guidelines for Investigators in the area of biotechnology. The workgroup, which also included Thaddeus T. Sze, Ph.D., Chemical Engineer, DFI, and Kim A. Rice, Supervisory Investigator, SEA-DO, prepared a draft document with information obtained from FDA Center and Field personnel who are actively involved in biotech inspections.

The document was reviewed and expanded upon during a 2 l/2 day workshop (May 29-3l, l99l) attended by the following Center and Field personnel: Wendy Aaronson (CBER), Henry Avallone (NWK- DO), Yuan-Yuan Chiu, Ph.D. (CDER), Vitolis Vengris, D.V.M., Ph.D. (CVM), John Ingalls (BOS-DO), Rita Jhangiani (PHI-DO), George Kroehling (CDRH), Seth Pauker, Ph.D. (OB), Pearl Tanjuaquio (LOS-DO), Frank Twardochleb (CDRH) and Sylvia Yetts (DAL-DO).

We wish to express our appreciation to all who shared inspection reports and FDA-483s, contributed technical expertise, provided comments, and assisted in the preparation of this Guide. Special thanks to Ms. Kimberly Search (DFI) for her expert clerical assistance.


CONTENTS

Subject                                            Page
Introduction....................................1
Cell Culture andFermentation....................3
AscitesProduction..............................10
Extraction,Isolation and Purification .........12
Cleaning Procedures............................16
Processing and Filling ........................18
Laboratory Controls............................21 
Testing .......................................22
Environmental Coverage ........................28
Appendix:
A. Flow Chart .................................30
B. Test Methods ...............................31
C. Glossary....................................37
D. References..................................46 
BIOTECHNOLOGY INSPECTION GUIDE FOR INVESTIGATORS 

INTRODUCTION

Biotechnology, defined as "the application of biological systems and organisms to technical and industrial processes", is not new. The use of yeast to ferment grain into alcohol has been ongoing for centuries. Likewise, farmers and breeders use a form of "genetic engineering" to produce improved crops and stock by selecting for desirable characteristics in plants and animals. Only recently have "new" biotechnology techniques enabled scientists to modify an organism's genetic material at the cellular or molecular level. These methods are more precise, but the results are similar to those produced with classical genetic techniques involving whole organisms. Biotechnology - derived products (BDP) used in this Guide refers to those products derived from the new biotechnology techniques.

The development of BDP and the inspection of the manufacture and control of these products offer many challenges. Because of the diversified manufacturing and control processes that are continuously being developed, considerable effort is required to achieve a level of technical competence to inspect these operations. Although the level of technology is increasing, it must be recognized that the same basic regulations and requirements are applicable to the manufacture and control of biotechnically- derived substances and devices as for "conventionally" manufactured products.

The same criteria have been used for many years in the inspection of manufacturers of antibiotics, enzymes and other high molecular weight substances including insulin, heparin, and albumin. This Guide will address some of the basic problems identified during inspections of manufacturers of BDP. Production systems may include animals, cell clones (e.g. hybridomas), mammalian and insect cell cultures, yeast, and bacteria or combinations of these systems.

A. Objective

B. Inspection Team

C. Inspection Approach

CELL CULTURE AND FERMENTATION

A. Master Cell Bank and Working Cell Bank

1. Origin and History

2. Characterization and Qualifying Tests

Information about the construction of the expression vector, the fragment containing the genetic material that encodes the desired product, and the relevant genotype and phenotype of the host cell(s) are submitted as part of a product application. The major concerns of biological systems are genetic stability of cell banks during production and storage, contaminating microorganisms, and the presence of endogenous viruses in some mammalian cell lines. As part of the application document, manufacturers will submit a description of all tests performed to characterize and qualify a cell bank.

It must be emphasized that the tests required to characterize a cell bank will depend on the intended use of the final product, the host/expression system and the method of production including the techniques employed for purification of the product. In addition, the types of tests may change as technology advances.

The MCB is rigorously tested. The following tests are generally performed, but are not limited to:

  • a. Genotypic characterization by DNA fingerprinting
  • b. Phenotypic characterization by nutrient requirements, isoenzyme analysis, growth and morphological characteristics
  • c. Reproducible production of desired product
  • d. Molecular characterization of vector/cloned fragment by restriction enzyme mapping, sequence analysis
  • e. Assays to detect viral contamination
  • f. Reverse transcriptase assay to detect retroviruses
  • g. Sterility test and mycoplasma test to detect other microbial contaminants
  • It is not necessary to test the WCB as extensively as the MCB; however, limited characterization of a WCB is necessary. The following tests are generally performed on the WCB, but this list is not inclusive:

  • a. Phenotypic characterization
  • b. Restriction enzyme mapping
  • c. Sterility and mycoplasma testing
  • d. Testing the reproducible production of desired product
  • 3. Storage Conditions and Maintenance

    4. Inspection Approach

    B. Media

    1. Raw Materials

      Raw materials used to prepare the media must be carefully selected to provide the proper rate of growth and the essential nutrients for the organisms producing the desired product. Raw materials should not contain any undesirable and toxic components that may be carried through the cell culture, fermentation and the purification process to the finished product. Water is an important component of the media and the quality of the water will depend on the recombinant system used, the phase of manufacture and intended use of the product. Raw materials considered to be similar when supplied by a different vendor should meet acceptance criteria before use. In addition, a small scale pilot run followed by a full-scale production run is recommended when raw materials from a different vendor are used, to assure that growth parameters, yield, and final product purification remain the same.

    2. Bovine Serum

      Most mammalian cell cultures require serum for growth. Frequently, serum is a source of contamination by adventitious organisms, especially mycoplasma, and firms must take precautions to assure sterility of the serum. Some Brazilian bovine serum (BBS) have been contaminated with hoof and mouth disease. Also make sure that the serum is indeed bovine serum and not derived from human sources.

      There is an additional concern that bovine serum may be contaminated with bovine spongiform encephalopathy (BSE) agent. BSE is a slow disease which has been detected in herds from the United Kingdom. Because there is no sensitive in vitro assay to detect the presence of this agent, it is essential that the manufacturers know the source of the serum and request certification that the serum does not come from areas where BSE is endemic. Other potential sources of BSE may be proteases and other enzymes derived from bovine sources. Biological product manufacturers have been requested to determine the origin of these materials used in manufacturing.

    3. Sterilization

      The media used must be sterilized. A sterilized in place (SIP) or a continuous sterilizing system (CSS) process is usually used. Any nutrients or chemicals added beyond this point must be sterile. Air lines must include sterile filters.

    4. Inspection Approach

  • a. Determine the source of serum.
  • b. Confirm that the sterilization cycle has been properly validated to ensure that the media will be sterile.
  • c. Verify that all raw materials have been tested by quality control. Determine the origin of all bovine material.
  • d. Document instances where the media failed to meet all specifications.
  • e. Verify that expired raw materials have not been used in manufacture.
  • f. Check that media and other additives have been properly stored.
  • C. Culture Growth

    ASCITES PRODUCTION

    Monoclonal antibodies can be produced in cell culture or in the abdomen of a mouse. There are unique critical points in ascites production that should be examined.

    A. Mouse Colony

    B. Manufacturing Processes

    EXTRACTION, ISOLATION AND PURIFICATION

    A. Introduction

    B. Process Types

    C. Description/Written Procedures

    D. Process Validation

    E. Process Water/Buffers/WFI

    F. Plant Environment

    CLEANING PROCEDURE

    A. Detailed Cleaning Procedure

    B. Sampling Plan

    C. Analytical Method/Cleaning Limits

    PROCESSING AND FILLING

    A. Processing

    B. In-Process Quality Control

    C. Filling

    D. Lyophilization

    LABORATORY CONTROLS

    A. Training

    B. Equipment Maintenance/Calibration/Monitoring

    C. Method Validation

    D. Standard/Reference Material

    E. Storage of Labile Components

    F. Laboratory SOPs

    TESTING

    A. Quality

    B. Identity

    C. Protein Concentration/Content

    D. Purity

    "Purity" means relative freedom from extraneous matter in the finished product, whether or not harmful to the recipient or deleterious to the product. Purity includes, but is not limited to, relative freedom from residual moisture or other volatile substances and pyrogenic substances. Protein impurities are the most common contaminants. These may arise from the fermentation process, media or the host organism. Endogenous retroviruses may be present in hybridomas used for monoclonal antibody production. Specific testing for these constituents is imperative in in vivo products. Removal of extraneous antigenic proteins is essential to assure the safety and the effectiveness of the product.

    Tests that may be encountered:

  • 1. Tests for Protein Impurities:
  • a. Electrophoresis
  • SDS PAGE
  • IEF
  • 2-Dimensional Electrophoresis
  • b. Peptide Mapping
  • c. Multiantigen ELISA
  • d. HPLC Size Exclusion HPLC Reverse Phase HPLC
  • 2. Tests for Non-Protein Impurities:
  • a. DNA Hybridization
  • b. HPLC
  • c. Pyrogen/Endotoxin Testing
  • U.S.P. Rabbit Pyrogen Test
  • Limulus Amebocyte Lysate (LAL) E
  • ndogenous Pyrogen Assay
  • Pyrogen Contamination - Pyrogenicity testing should be conducted by injection of rabbits with the final product or by the limulus amebocyte lysate (LAL) assay. The same criteria used for acceptance of the natural product should be used for the biotech product.

    The presence of endotoxins in some in vitro diagnostic products may interfere with the performance of the device. Also, it is essential that in vivo products be tested for pyrogens. Certain biological pharmaceuticals are pyrogenic in humans despite having passed the LAL test and the rabbit pyrogen test. This phenomenon may be due to materials that appear to be pyrogenic only in humans. To attempt to predict whether human subjects will experience a pyrogenic response, an endogenous pyrogen assay is used. Human blood mononuclear cells are cultured in vitro with the final product, and the cell culture fluid is injected into rabbits. A fever in the rabbits indicates the product contains a substance that may be pyrogenic in humans.

    Tests that may be encountered:

      1. U.S.P. Rabbit Pyrogen Test
      2. Limulus Amebocyte Lysate (LAL)
      3. Assay Endogenous Pyrogen Assay

    Viral Contamination - Tests for viral contamination should be appropriate to the cell substrate and culture conditions employed. Absence of detectable adventitious viruses contaminating the final product should be demonstrated.

    Tests that may be encountered:

      1. Cytopathic effect in several cell types
      2. Hemabsorption Embryonated Egg Testing
      3. Polymerase Chain Reaction (PCR)
      4. Viral Antigen and Antibody Immunoassay
      5. Mouse Antibody Production (MAP)

    Nucleic Acid Contamination - Concern about nucleic acid impurities arises from the possibility of cellular transformation events in a recipient. Removal of nucleic acid at each step in the purification process may be demonstrated in pilot experiments by examining the extent of elimination of added host cell DNA. Such an analysis would provide the theoretical extent of the removal of nucleic acid during purification.

    Direct analyses of nucleic acid in several production lots of the final product should be performed by hybridization analysis of immobilized contaminating nucleic acid utilizing appropriate probes, such as nick-translated host cell and vector DNA. Theoretical concerns regarding transforming DNA derived from the cell substrate will be minimized by the general reduction of contaminating nucleic acid.

    Tests that may be encountered:

      1. DNA Hybridization (Dot Blot)
      2. Polymerase Chain Reaction (PCR)

    Protein Contamination

    Tests that may be encountered for product-related proteins:

      1. SDS PAGE
      2. PLC
      3. IEF

    Tests that may be encountered for foreign proteins:

    1. Immunoassays
    2. Radioimmunoassays
    3. ELISA
    4. Western Blot
    5. SDS Page
    6. 2-Dimensional Electrophoresis

    Microbial Contamination - Appropriate tests should be conducted for microbial contamination that demonstrate the absence of detectable bacteria (aerobes and anaerobes), fungi, yeast, and mycoplasma, when applicable.

    Tests that may be encountered:

      1. U.S.P. Sterility Test
      2. Heterotrophic Plate Count and Total Yeasts and Molds
      3. Total Plate Count
      4. Mycoplasma Test
      5. LAL/Pyrogen

    Chemical Contaminants - Other sources of contamination must be considered, e.g., allergens, petroleum oils, residual solvents, cleaning materials, column leachable materials, etc.

    E. Potency (Activity)

    "Potency" is interpreted to mean the specific ability or capacity of the product, as indicated by appropriate laboratory tests or by adequately controlled clinical data obtained through the administration of the product in the manner intended, to produce a given result. Tests for potency should consist of either in vitro or in vivo tests, or both, which have been specifically designed for each product so as to indicate its potency. A reference preparation for biological activity should be established and used to determine the bioactivity of the final product. Note: Where applicable, in-house biological potency standards should be cross-referenced against international (World Health Organization (WHO), National Institute of Biological Standards and Control (NIBSC)) or national (National Institutes of Health (NIH), National Cancer Institute (NCI), Food and Drug Administration (FDA)) reference standard preparations, or USP standards.

    Tests that may be encountered:

    1. Validated method of potency determination
    2. Whole Animal Bioassays
    3. Cell Culture Bioassays
    4. Biochemical/Biophysical Assays
    5. Receptor Based Immunoassays
    6. Potency Limits
    7. Identification of agents that may adversely affect potency
    8. Evaluation of functional activity and antigen/antibody specificity
    9. Various immunodiffusion methods (single/double)
    10. Immunoblotting/Radio-or Enzyme-linked Immunoassays
    11. HPLC-validated to correlate certain peaks to biological activity

    F. Stability

    "Stability" is the capacity of a product to remain within specifications established to ensure its identity, strength, quality, purity, safety, and effectiveness as a function of time. Studies to support the proposed dating period should be performed on the final product. Real-time stability data would be essential to support the proposed dating period. Testing might include stability of potency, pH, clarity, color, particulates, physiochemical stability, moisture and preservatives. Accelerated stability testing data may be used as supportive data. Accelerated testing or stress tests are studies designed to increase the ratio of chemical or physical degradation of a substance or product by using exaggerated storage conditions. The purpose is to determine kinetic parameters to predict the tentative expiration dating period. Stress testing of the product is frequently used to identify potential problems that may be encountered during storage and transportation and to provide an estimate of the expiration dating period. This should include a study of the effects of temperature fluctuations as appropriate for shipping and storage conditions. These tests should establish a valid dating period under realistic field conditions with the containers and closures intended for the marketed product.

    Some relatively fragile biotechnically-derived proteins may require gentle mixing and processing and only a single filtration at low pressure. The manufacturing directions must be specific with maximum filtration pressures given in order to maintain stability in the final product. Products containing preservatives to control microbial contamination should have the preservative content monitored. This can be accomplished by performing microbial challenge tests (i.e. U.S.P. Antimicrobial Preservative Effectiveness Test) or by performing chemical assays for the preservative. Areas that should be addressed are:

    - Effective monitoring of the stability test environment (i.e. light, temperature, humidity, residual moisture);

    - Container/closure system used for bulk storage (i.e. extractables, chemical modification of protein, change in stopper formulations that may change extractable profile);

    - Identify materials that would cause product instability and test for presence of aggregation, denaturation, fragmentation, deamination, photolysis, and oxidation;

    - Tests to determine aggregates or degradation products.

    Tests that may be encountered:

    1. SDS PAGE
    2. IEF
    3. HPLC
    4. Ion Exchange Chromatography
    5. Gel Filtration
    6. Peptide Mapping
    7. Spectrophotometric Methods
    8. Potency Assays
    9. Performance Testing
    10. 2-Dimensional Electrophoresis

    G. Batch To Batch Consistency

    ENVIRONMENTAL COVERAGE

    Environmental/biocontainment coverage for biotechnology facilities should be conducted as part of regular GMP inspections, particularly pre-approval or pre-licensing inspections. FDA is responsible under the National Environmental Policy Act (NEPA) for ascertaining the environmental impact that may occur due to the manufacture, use, and disposal of FDA regulated products. No other federal or state regulatory agency can be informed by FDA of the existence of an unapproved product application. Consequently, FDA must also make sure that the product sponsor is conducting investigations safely.

    A. Environmental Assessments

    B. Inspection Approach

    APPENDIX:

    A. FLOW CHART

    [Graphic: Flow Chart]

    B. TEST METHODS

    C. GLOSSARY

    D. REFERENCES

    Books and Literature

    1. Antebi, E. and Fishlock, D., Biotechnology - Strategies for Life. MIT Press, Cambridge, MA (1986).

    2. Avallone, H.L., Beatrice, M.G., and Sze, T.T. Food and Drug Administration Inspection and Licensing of Manufacturing Facilities. Drug Biotechnology Regulation, Y.- y.H. Chiu and J.L. Gueriguian, Ed., 315- 340 (1991)

    3. Biotechnology Quality Control Training Course Manual by PMA (1991).

    4. Campbell, A.M., Laboratory Techniques in Biochemistry and Molecular Biology - Monoclonal Antibody Technology, Volume 13, Elsevier, New York (1986).

    5. Chiu, Y.- y.H. Validation of the Fermentation Process for the Production of Recombinant DNA Drugs. Pharm. Technol 12:132. (1988).

    6. Chiu, Y.- y.H. Review and Discussion of Special Chemical and Pharmaceutical Requirements in the U.S. for Biotechnology Products. Drug Information Journal 23:47 (1989).

    7. Davis, B.D., Dulbecco, R., Eisen, H. and Ginsberg, H. in Microbiology, 3rd edition. Maryland, Harper & Row (1980).

    8. Dorland's Pocket Medical Dictionary (23rd Edition), W. B. Saunders Company (1982).

    9. Emery, A.E.H., An Introduction to Recombinant DNA, John Wiley and Sons, New York (1984).

    10. "Genetic Engineering, A Natural Science," Monsanto Company, St. Louis, Mo. (1985).

    11. Hanson, L.A. and Wigzell, H., Immunology, Butterworths, Boston (1985).

    12. Smith, B.- H. FDA Enforcement in Bioprocessing Facilities. ASTMSTP 1051 W.C. Hyer, Jr., Ed., 152- 157 (1990).

    13. Tetzlaff, R.F. FDA Regulatory Inspections of Aseptic Processing Facilities. Aseptic Pharmaceutical Manufacturing, W.P. Olson and M.J. Groves, Ed., 367- 401 (1987).

    14. "What Is Biotechnology?" Industrial Biotechnology Association (1984).

    FDA and Other Government Publications

    1. Biotech Inspection Outline (1988).

    2. Cytokine and Growth Factor Pre- approval Trial Information Package (1990).

    3. Federal Register Coordinated Framework for Regulation of Biotechnology. 51:23303- 23393 (1986).

    4. Guide to Inspection of Computerized Systems in Drug Processing (1983).

    5. Guideline for Submitting Documentation for the Stability of Human Drugs and Biologics (1987).

    6. Guideline for the Manufacture of In Vitro Diagnostic Products (1990).

    7. Guideline on the General Principles of Process Validation (1987).

    8. Guidelines on Validation of the Limulus Amebocyte Lysate Test as an End- Product Endotoxin Test for Human and Animal Parenteral Drugs, Biologics and Medical Devices (1987).

    9. Inspection Technical Guide No. 43 Lyophilization of Parenterals (1986).

    10. Interferon Test Procedures: Points to be Considered in the Production and Testing of Interferon intended for Investigational Use in Humans (1983).

    11. National Institutes of Health. Recombinant DNA Research; Action under Guidelines. Fed. Reg. 52:31848- 31850 (1987) 53:43410- 43411 (1988); 56:33174- 33183 (1991).

    12. Points to Consider in the Characterization of Cell Lines to Produce Biological Products (1987).

    13. Points to Consider in the Collection, Processing, and Testing of Ex- Vivo Activated Mononuclear Leucocytes for Human Use (1989).

    14. Points to Consider in the Manufacture and Clinical Evaluation of In Vitro Tests to Detect Antibodies to the Human Immunodeficiency Virus (1989).

    15. Points to Consider in the Manufacturing of In Vitro Monoclonal Products Subject of Licensure (1983).

    16. Consider in the Manufacturing of Monoclonal Antibody Products for Human Use (1987).

    17. Points to Consider in the Production and Testing of New Drugs and Biologics Produced by Recombinant DNA Technology (1985).

    18. Recommended Test Procedures for Mycoplasmas (1988).